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Case3:13-cv-01752-EMC Document21 Filed10/21/13 Page1 of 3



Michele R. Stafford, Esq. (SBN 172509)
Shivani Nanda (SBN 253891)
SALTZMAN & JOHNSON LAW CORPORATION
44 Montgomery Street, Suite 2110
San Francisco, CA 94104
Telephone: (415) 882-7900
Facsimile: (415) 882-9287
[email protected]
[email protected]

Attorneys for Plaintiffs




UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA













Plaintiffs,

v.



BAY AREA PAINTERS AND TAPERS
PENSION TRUST FUND, et al.,






REYES DRYWALL, INC. and DOES 1-10,
inclusive;





Defendant.

















Case No.: C13-1752 EMC

STIPULATION AND [PROPOSED] ORDER
TO EXTEND MEDIATION COMPLETION
DEADLINE BY SIXTY DAYS


The parties to this action hereby respectfully request and stipulate to extend the deadline to

hold the mediation session by 60 days. Good cause exists for the continuance, as follows:

1.

On July 15, 2013, the Court ordered the parties to participate in mediation within

the presumptive deadline of ninety days. (Docket No. 15).

2.

On August 12, 2013, ADR Clerk, Richard Wieking notified the parties that

Katherine Ritchey was the assigned mediator for this case. (Docket No. 19).

3.

On August 19, 2013, the parties participated in a pre-mediation conference with

Ms. Ritchey and scheduled the mediation for October 14, 2013.

4.

The parties are currently engaged in settlement discussions and are close to

resolving this matter. To avoid the time and expense of preparing for and attending mediation, the

parties agreed to cancel the October 14, 2013 mediation and continue informal settlement

discussions.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC

P:\CLIENTS\PATCL\Reyes Drywall Inc. (Patterson) 2 REYESD2\Pleadings\C13-1752 EMC Stipulation and Proposed Order to Extend Mediation Deadline 101513.doc

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Case3:13-cv-01752-EMC Document21 Filed10/21/13 Page2 of 3



5.

If the matter does not resolve informally, the parties have agreed to reschedule a

mediation session with Ms. Ritchey.

6.

The parties therefore request that the Court extend the deadline to hold the

mediation session by 60 days.
Dated: October 15, 2013






Dated: October 15, 2013








By:





By:


SALTZMAN & JOHNSON
LAW CORPORATION


/S/

Shivani Nanda
Attorneys for Plaintiffs


LAW OFFICE OF
GEORGE R. GORE


/S/

George R. Gore
Attorney for Defendant

IT IS SO ORDERED.
The deadline

to hold

the mediation session

is extended by sixty days

to

_______________________, 2013.
Date: ____________________












_________________________________________
THE HONORABLE EDWARD M. CHEN
UNITED STATES DISTRICT COURT



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STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC

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12/15The CMC originally set for 11/7/13 is reset for 1/16/14 at 10:30 a.m. An updated CMC statement shall be filed by 1/9/14.10/21/13UNITEDSTATESDISTRICTCOURTNORTHERNDISTRICTOFCALIFORNIAIT IS SO ORDEREDAS MODIFIEDJudge Edward M. ChenCase3:13-cv-01752-EMC Document21 Filed10/21/13 Page3 of 3





ATTESTATION CERTIFICATE

In accord with the Northern District of California’s General Order No. 45, Section X(B), I

attest that concurrence in the filing of this document has been obtained from each of the other

signatories who are listed on the signature page.

Dated: October 15, 2013










By:




SALTZMAN & JOHNSON
LAW CORPORATION


/S/

SHIVANI NANDA
Attorneys for Plaintiffs

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ATTESTATION CERTIFICATE RE: STIPULATION AND [PROPOSED] ORDER TO EXTEND
MEDIATION COMPLETION DEADLINE
CASE NO.: C13-1752 EMC

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