Free Stipulation - District Court of California - California

Case 4:07-cv-03944-SBA

Document 63

Filed 08/08/2008

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11

MARGARET HART EDWARDS, Bar No. 65699 JOSHUA D. KIENITZ, Bar No. 244903 LITTLER MENDELSON A Professional Corporation 650 California Street, 20th Floor San Francisco, CA 94108.2693 Telephone: 415.433.1940 Attorneys for Defendant GEORGIA-PACIFIC CORRUGATED, LLC

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, el al., Plaintiffs, Case No. C 07 3944 SBA STIPULATED REQUEST FOR CONTINUANCE OF DISCOVERY DEADLINES AND TRIAL CALENDAR

12 v. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
LIT T LE R ME NDE LSO N
A P R O F E S S I ON A L C O RP O R AT I O N 650 C a lifornia Stre e t 20th F loor Sa n F ra ncisco, C A 94108. 2693 415. 433. 1940

GEORGIA-PACIFIC CORRUGATED, LLC, Defendant.

Defendant Georgia-Pacific Corrugated ("G-P" or "Defendant"), Plaintiff Equal Employment Opportunity Commission ("EEOC"), and Plaintiff/Intervenor Janet Stege ("Stege") hereby jointly and urgently request that this Court issue an Order continuing the discovery deadlines and trial calendar for this case for not less than 60 days. Pursuant to this Court's order of August 4, 2008 (see Docket No. 61), the Parties met for a settlement conference before Magistrate Wayne D. Brazil on August 7, 2008. In order to open up their schedules to meet for this settlement conference, and in order to avoid incurring further costs and attorneys' fees (and thereby make settlement less likely), the Parties were forced to take several previously-noticed depositions off calendar. Taking these depositions off calendar proved to be a productive choice. Magistrate Brazil summarized the significant progress made by the Parties on August 7, 2008 as follows: "2 good ideas (one from each side). Parties continue negotiations." See Docket No. 62. After the
Stip Re Continuance Of Discovery Deadlines And Trial Calendar; [Proposed] Order

1.

Case No. C 07 3944 SBA

Case 4:07-cv-03944-SBA

Document 63

Filed 08/08/2008

Page 2 of 4

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
LIT T LE R ME NDE LSO N
A P R O F E S S I ON A L C O RP O R AT I O N 650 C a lifornia Stre e t 20th F loor Sa n F ra ncisco, C A 94108. 2693 415. 433. 1940

settlement conference, the Parties met for more than an hour in the witness rooms outside of the Magistrate's courtroom. The "2 good ideas" referenced by Magistrate Brazil represent substantial political, monetary, and practical concessions from each of Plaintiff EEOC, Plaintiff/Intervenor Janet Stege, and Defendant G-P. All Parties have indicated that these substantial concessions are possible only if this case settles before trial. The Parties sincerely wish to build on the progress made in this settlement conference and quickly to reach a settlement agreement. However, because the current fact discovery deadline, September 2, 2008, is fast approaching, this will only be possible with a continuance of discovery deadlines and the trial calendar. The Parties have noticed (and then taken off calendar) several critical depositions, all of which cannot possibly be completed before the current fact discovery cutoff. Further, the cost, both in money and time, of conducting these depositions will make achieving settlement significantly less likely. The Parties have met three separate times in an attempt to reach settlement: (1) in an ADR mediation conference on April 24, 2008; (2) in a several-hour meeting on July 17, 2008; and (3) in the settlement conference before Magistrate Brazil. Each meeting has been more successful than the prior one, and the Parties stand on the edge of reaching settlement. Because the discovery cutoff date is fast approaching, the Parties request that Your Honor, the general duty judge, sign the proposed order, filed concurrently herewith, in Judge Armstrong's absence. SO STIPULATED: I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document. Date: August 8, 2008 EQUAL EMPLOYMENT COMMISSION OPPORTUNITY

/s/ Linda Ordonio-Dixon Linda Ordonio-Dixon Attorney for Plaintiff EEOC

Stip Re Continuance Of Discovery Deadlines And Trial Calendar; [Proposed] Order

2.

Case No. C 07 3944 SBA

Case 4:07-cv-03944-SBA

Document 63

Filed 08/08/2008

Page 3 of 4

1 Date: August 8, 2008 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
LIT T LE R ME NDE LSO N
A P R O F E S S I ON A L C O RP O R AT I O N 650 C a lifornia Stre e t 20th F loor Sa n F ra ncisco, C A 94108. 2693 415. 433. 1940

DICKSON ­ ROSS LLP

/s/ Kathryn Burkett Dickson Kathryn Burkett Dickson Attorney for Plaintiff/Intervenor Janet Stege

Date: August 8, 2008

LITTLER MENDELSON, P.C.

/s/ Margaret Hart Edwards Margaret Hart Edwards Attorney for Defendant Georgia-Pacific Corrugated, LLC

Stip Re Continuance Of Discovery Deadlines And Trial Calendar; [Proposed] Order

3.

Case No. C 07 3944 SBA

Case 4:07-cv-03944-SBA

Document 63

Filed 08/08/2008

Page 4 of 4

1 2 3 4 5 6 Plaintiffs, 7 v. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
LIT T LE R ME NDE LSO N
A P R O F E S S I ON A L C O RP O R AT I O N 650 C a lifornia Stre e t 20th F loor Sa n F ra ncisco, C A 94108. 2693 415. 433. 1940

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, el al.,

Case No. C 07 3944 SBA [PROPOSED] ORDER CONTINUING DISCOVERY DEADLINES AND TRIAL CALENDAR

GEORGIA-PACIFIC CORRUGATED, LLC, Defendant.

For good cause shown and pursuant to the Stipulation of the Parties that they have made significant progress toward a settlement, inter alia, through meeting with Magistrate Wayne D. Brazil on August 7, 2008 (see Docket No. 62), it is hereby ordered that all discovery deadlines be continued for 60 days. If a 60-day continuance would result in a deadline falling on a weekend, such deadline shall be set for the following Monday. If this case has not yet settled, the parties shall appear via telephone on ___________, 2008 for a case management conference in order to set a new trial date for this matter.

Date: United States District Judge

Firmwide:86155021.1 053676.1002

Stip Re Continuance Of Discovery Deadlines And Trial Calendar; [Proposed] Order

1.

Case No. C 07 3944 SBA