Free Declaration in Support - District Court of California - California

Case 3:07-cv-05099-JSW

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Filed 01/14/2008

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Bingham McCutchen LLP ROBERT A. LEWIS (SBN 83630) [email protected] ALAN R. BERKOWITZ (SBN 50112) [email protected] BRYAN E. DALEY (SBN 227517) [email protected] Three Embarcadero Center San Francisco, CA 94111-4067 Telephone: 415.393.2000 Facsimile: 415.393.2286 Attorneys for Defendant Claudia Rockseth-Shipman UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

JLT AEROSPACE (NORTH AMERICA), INC., a corporation, Plaintiff, v. CLAUDIA ROCKSETH-SHIPMAN, Defendant.

No. C 07-5099 (JSW) DECLARATION OF BRYAN DALEY IN SUPPORT OF PLAINTIFF AND DEFENDANT'S STIPULATED REQUEST FOR AN ORDER CONTINUING THE PARTIES' CASE MANAGEMENT CONFERENCE AND EXTENDING DEFENDANT'S DEADLINE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT (N.D. Cal. Local Rule 6-2; FRCP 6(b))

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A/72330798.1/2000047-0000328979

DALEY DECL. IN SUPPORT OF STIPULATED REQUEST FOR AN ORDER CONTINUING THE CMC AND EXTENDING DEFENDANT'S DEADLINE TO ANSWER/RESPOND (Case No. C 07-5099 (JSW))

Case 3:07-cv-05099-JSW

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Filed 01/14/2008

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Bryan Daley declares: 1. I am an associate of Bingham McCutchen LLP, counsel of record for

defendant Claudia Rockseth-Shipman in this action. I have personal knowledge of the facts set forth in this Declaration and would be competent to testify to them if called upon to do so. 2. The Court has previously ordered two time modifications in this case. On

October 26, 2007 and December 14, 2007, the Court entered orders approving the parties' stipulations that Defendant's deadline to answer or otherwise respond to Plaintiff's Complaint would be extended. 3. In the parties' Stipulated Request, filed concurrently with this Declaration,

the parties ask the Court to continue the parties' case management conference and to extend Defendant's deadline to answer or otherwise respond to Plaintiff's Complaint. The continuance and extension are appropriate because, in a related matter, JLT Aerospace ("JLT") and Ms. Shipman's employer, Marsh USA, Inc. ("Marsh"), agreed to a plan providing for informal discovery and a timetable for conducting good-faith, in-person settlement negotiations that if successful would also settle the present action. In accordance with that agreement, the parties will be conducing an in-person mediation session on January 18, 2008. Granting the parties' stipulated request will allow the parties to focus on their settlement efforts and, if the parties settle, will save the parties and the Court from the time and expense of the procedures currently scheduled.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 14th day of January, 2008 in San Francisco, California.

/s/ Bryan Daley Bryan Daley

A/72330798.1/2000047-0000328979

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DALEY DECL. IN SUPPORT OF STIPULATED REQUEST FOR AN ORDER CONTINUING THE CMC AND EXTENDING DEFENDANT'S DEADLINE TO ANSWER/RESPOND (Case No. C 07-5099 (JSW))