Free Motion to Vacate - District Court of California - California

Case 3:07-cv-02295-JAH-CAB

Document 16

Filed 09/19/2008

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KAREN P. HEWITT United States Attorney TIMOTHY C. STUTLER Assistant U.S. Attorney California State Bar No. 131794 Federal Office Building 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7387 Attorneys for the Defendant Paul D. Jackson, Cal. St. Bar No. 59542 LAW OFFICES OF PAUL D. JACKSON 10951 Sorrento Valley Road, Suite 1-G San Diego, CA 92121-1613 Voice (858) 552-4900 Fax (858) 552-4904

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) Plaintiff, ) ) v. ) ) ) DONALD C. WINTER in his official capacity as SECRETARY OF THE NAVY, ) ) ) Defendant. ) LONNIE J. JONES, Civil No. 07cv2295JAH(CAB)

JOINT MOTION TO VACATE MANDATORY SETTLEMENT CONFERENCE

COME NOW THE PARTIES, Plaintiff Lonnie J. Jones, by and through his counsel,
Paul D. Jackson, Esq., and Defendant Donald C. Winter, Secretary of the Navy, by and

through his counsel, Karen P. Hewitt, United States Attorney, and Timothy C. Stutler, Assistant United States Attorney, and hereby jointly move the Court to vacate the Mandatory Settlement Conference set for September 30,2008 in this matter. Because the parties have not completed their discovery, and because Defendant intends to file a summary judgment motion, the parties agree that settlement efforts at this stage of the litigation would not be productive. The discovery cut-off date in this matter is November 28, 2008. The last date to file a summary judgment motion is January 5, 2009.
07cv2295

Case 3:07-cv-02295-JAH-CAB

Document 16

Filed 09/19/2008

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Based on a conversation between Defendant's counsel and chambers earlier today, the parties do not plan to file Mandatory Settlement Conference Statements at this time, unless directed to do so by the Court. Dated: September 19, 2008
LAW OFFICES OF PAUL D. JACKSON

s/ Paul D. Jackson
6 7 PAUL D. JACKSON

Attorney for Plaintiff Dated: September 19, 2008
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KAREN P. HEWITT United States Attorney s/ Timothy C. Stutler TIMOTHY C. STUTLER Assistant U.S. Attorney Attorneys for Defendant

Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures of the United States District Court for the Southern District of California, I certify that the content of this document is acceptable to counsel for the Plaintiff, Paul D. Jackson, Esq., and that I have obtained authorization from Mr. Jackson to affix his electronic signature to this document. Dated: September 19, 2008 KAREN P. HEWITT United States Attorney s/ Timothy C. Stutler TIMOTHY C. STUTLER Assistant U.S. Attorney Attorneys for Defendant

Case 3:07-cv-02295-JAH-CAB

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Filed 09/19/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Paul D. Jackson, Esq., LAW OFFICES OF PAUL D. JACKSON, [email protected] I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on September 19, 2008. s/ Timothy C. Stutler TIMOTHY C. STUTLER
07cv2295

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) v. ) ) ) DONALD C. WINTER in his official ) capacity as SECRETARY OF THE NAVY, ) ) Defendant. ) ) IT IS HEREBY CERTIFIED THAT: I, Timothy C. Stutler, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of the following document(s) on the parties indicated below by electronically filing said document(s) with the Clerk of the District Court using its ECF System, which electronically notifies them: DOCUMENT(S) SERVED: LONNIE J. JONES, Civil No. 07cv2295JAH(CAB) CERTIFICATE OF SERVICE

JOINT MOTION TO VACATE MANDATORY SETTLEMENT CONFERENCE
PARTIES ON WHOM SERVED: