Attorney(s) appearing for the Case
Nicole Moss, Plaintiff, represented by Michael Edmund Gatto , Rains Lucia Stern, PC.
Nicole Moss, Plaintiff, represented by Paul Leslie Rein , Law Offices of Paul L. Rein & Celia Louise McGuinness , Derby, McGuinness & Goldsmith, LLP.
City and County of San Francisco, Defendant, represented by Thomas Spencer Lakritz , OFFICE OF THE CITY ATTORNEY.
[PROPOSED] ORDER TO EXTEND DEADLINE TO MEDIATE UNDER GENERAL ORDER 56
KANDIS A. WESTMORE, Magistrate Judge.
Plaintiff NICOLE MOSS ("Plaintiff") and Defendant CITY AND COUNTY OF SAN FRANCISCO hereby jointly stipulate and request through their attorneys of record that the deadline to Mediation under General Order 56 be continued from March 7, 2017, until May 31, 2017. The relevant history of the case is as follows:
1. The original date for filing a Notice of Need for Mediation was June 1, 2016, Docket No. 4.
2. Because the scope of the facilities at San Francisco General Hospital required more time than usual for access experts to prepare a report, the parties stipulated to extend the deadline for Plaintiff to file the Notice of Need for Mediation to December 15, 2016. Docket No. 32.
3. Plaintiff filed the Notice of Need for Mediation on December 7, 2016. Docket No. 34.
4. The case was assigned a mediator on January 17, 2017. Docket No. 35.
5. Pursuant to General Order 56, the parties have 90 days from filing the Notice of Need for Mediation to complete the mediation. Thus, the deadline to complete mediation is March 7, 2017.
This request for an extension of time is based on the following good cause:
1. The parties have worked cooperatively to move through General Order 56.
2. The parties have engaged in significant pre-mediation discussion via telephone conference and email, facilitated by ADR Director Howard Herman.
3. The Parties agreed to join into this mediation another case, Moss v. Kindred Healthcare Operating, Inc. et al., 4:16-cv-00657 YGR. The City of San Francisco is a defendant in that matter as well. The Parties believe that mediating the cases together will facilitate a more efficient resolution of all issues.
4. Due to the number of party representatives and attorneys involved in the two matters, the Parties were unable to find a mutually agreeable date for mediation within the Court's deadline.
5. All parties have agreed to participate in mediation on May 9, 2017. Therefore, in an effort to keep costs down and to facilitate efficient resolution of the case through mediation and the General Order 56 process, the Parties stipulate and request that the Court order the deadline for mediation to take place under General Order 56 be extended to May 31, 2017. THE LAW OFFICE OF PAUL L. REIN
Pursuant to the stipulation of the parties, and for good cause shown, IT IS SO ORDERED. The deadline for the parties to mediate under General Order 56 is hereby continued to May 31, 2017.
Pursuant to Local Rule 5-1, I hereby attest that on March 3, 2017, I, Celia McGuinness, attorney with The Law Office of Paul L. Rein., received the concurrence of Thomas S. Lakritz in the filing of this document.