Free Stipulation and Order - District Court of California - California

Case 3:08-cv-00766-SC

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AYANNA L. JENKINS TONEY, ESQ. (SBN 224847) Law Offices Of Ayanna L. Jenkins Toney 225 Bush Street 16th Floor San Francisco, CA 94104 Telephone: (415) 464-4974 Facsimile: (415) 464-4975 Email: [email protected] Attorney for Plaintiff ISOLINA PICON MICHAEL P. MURPHY, COUNTY COUNSEL (SBN 83887) By: John D. Nibbelin, Deputy (SBN 184603) By: Glenn M. Levy, Deputy (SBN 219029) Hall of Justice and Records 400 County Center, 6th Floor Redwood City, CA 94063 Telephone: (650) 363-4757 Facsimile: (650) 363-4034 Email: [email protected] [email protected] Attorneys for Defendants COUNTY OF SAN MATEO and ROBERT FOUCRAULT, individually and as Coroner, San Mateo County UNITED STATES DISTRICT COURT NORTHERN DISTICT OF CALIFORNIA ISOLINA PICON, Plaintiff, vs. COUNTY OF SAN MATEO, ROBERT FOUCRAULT, individual and as Coroner, SAN MATEO COUNTY Defendants. Case No. C-08-0766 SC [PROPOSED] ORDER AND STIPULATION REGARDING MEDIATION DEADLINE

Case No. C-08-0766 SC [PROPOSED] ORDER AND STIPULATION REGARDING MEDIATION DEADLINE

Case 3:08-cv-00766-SC

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The parties to this litigation, through their respective counsel of record, hereby note the following facts and accordingly stipulate as follows: On May 8, 2008, the Court ordered this case to mediation pursuant to the ADR stipulation filed by the parties. That order requires the parties to hold the ADR session by August 6, 2008. On May 15, 2008, the Court appointed Daniel Bowling of the United States District Court's ADR Unit as the mediator for this case. On June 11, 2008, the parties through their respective counsel had a pre-mediation telephone conference with Mr. Bowling. During the course of that telephone conference the parties and Mr. Bowling agreed that the mediation would benefit from being scheduled after a ruling on the Defendant's pending Rule 12(b)(6) motion. In light of this view, the parties and Mr. Bowling agreed that the parties should request an extension of the deadline for holding the ADR session until September 30, 2008, which will permit for scheduling of the mediation and accommodation of other upcoming commitments. Accordingly, the parties hereby stipulate and request that the Court extend the deadline for holding the ADR session through and including September 30, 2008.

Dated: June 13, 2008

Respectfully submitted, MICHAEL P. MURPHY, COUNTY COUNSEL

By:

/s/ Glenn M. Levy, Deputy

Attorneys for Defendants COUNTY OF SAN MATEO and ROBERT FOUCRAULT, individually and as Coroner, San Mateo County

Case No. C-08-0766 SC 1 [PROPOSED] ORDER AND STIPULATION REGARDING MEDIATION DEADLINE

Case 3:08-cv-00766-SC

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Case 3:08-cv-00766-SC

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Case No. C-08-0766 SC 2 [PROPOSED] ORDER AND STIPULATION REGARDING MEDIATION DEADLINE

LAW OFFICES OF AYANNA L. JENKINS TONEY

By: Ayanna L. Jenkins Toney, Esq. Attorney for Plaintiff ISOLINA PICON Pursuant to the stipulation above, the ADR session in the above-captioned matter is to be held no later than September 30, 2008.

IT IS SO ORDERED.

Dated: _____________, 2008 Judge Samuel Conti UNITED STATES DISTRICT JUDGE