Free Stipulation - 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) 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/72330768.1/2000047-0000328979

PLAINTIFF AND DEFENDANT'S 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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THE PARTIES STIPULATE THROUGH THEIR COUNSEL AS FOLLOWS: 1. In October 2007, 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. 2. On December 17, the Court agreed to extend Defendant Shipman's deadline to answer or otherwise respond to Plaintiff's Complaint to January 15, 2008. On December 18, the Court ordered that the parties' initial case management conference ("CMC") would be held on February 8, 2008. 3. In the related action, JLT and Marsh have agreed to participate in an in-person mediation session on January 18, 2008, during which this present matter may be resolved. 4. The parties believe that a continuance of the CMC and a further extension of Ms. Shipman's deadline to answer or otherwise respond to JLT's Complaint will allow JLT and Marsh to focus on the mediation scheduled for January 18, 2008 in the related matter which will also, if successful, settle the present matter without the need for protracted litigation. 5. The parties therefore request that the Court: (1) Continue the parties' CMC by 7 days to February 15, 2008; and (2) Extend Defendant's deadline to answer or otherwise respond to Plaintiff's Complaint by a further ten days to January 25, 2008. SO STIPULATED. DATED: January 14, 2008 BINGHAM McCUTCHEN LLP By: /s/ Bryan Daley Bryan E. Daley Attorneys for Defendant Claudia Rockseth-Shipman DATED: January 14, 2008 COOK | ROOS | WILBUR | THOMPSON LLP By: /s/ Susan H. Roos Susan H. Roos Attorneys for Plaintiff JLT Aerospace (North America), Inc.

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PLAINTIFF AND DEFENDANT'S 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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ATTESTATION CLAUSE I, Bryan E. Daley, am the ECF user whose ID and password are being used to file this 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. In compliance with General Order 45, X.B., I hereby attest that Susan H. Roos has concurred in this filing.

DATED: January 14, 2008

BINGHAM McCUTCHEN LLP

By: /s/ Bryan Daley Bryan E. Daley Attorneys for Defendant Claudia Rockseth-Shipman

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