Filed: Mar. 04, 2013
Latest Update: Mar. 04, 2013
Summary: STIPULATION AND [PROPOSED] ORDER MODIFYING INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES SCHEDULE SAUNDRA BROWN ARMSTRONG, District Judge. Pursuant to Local Rules 6-2(a) and 7-12 of the Northern District's Civil Local Rules, Plaintiff Andres Jimenez, (Plaintiff), through his attorneys, respectfully stipulate, subject to the Court's consideration and approval, as follows: 1. On December 18, 2012, plaintiff filed his Complaint. 2. On January 8, 2013 plaintiff served the summons and comp
Summary: STIPULATION AND [PROPOSED] ORDER MODIFYING INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES SCHEDULE SAUNDRA BROWN ARMSTRONG, District Judge. Pursuant to Local Rules 6-2(a) and 7-12 of the Northern District's Civil Local Rules, Plaintiff Andres Jimenez, (Plaintiff), through his attorneys, respectfully stipulate, subject to the Court's consideration and approval, as follows: 1. On December 18, 2012, plaintiff filed his Complaint. 2. On January 8, 2013 plaintiff served the summons and compl..
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STIPULATION AND [PROPOSED] ORDER MODIFYING INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES SCHEDULE
SAUNDRA BROWN ARMSTRONG, District Judge.
Pursuant to Local Rules 6-2(a) and 7-12 of the Northern District's Civil Local Rules, Plaintiff Andres Jimenez, (Plaintiff), through his attorneys, respectfully stipulate, subject to the Court's consideration and approval, as follows:
1. On December 18, 2012, plaintiff filed his Complaint.
2. On January 8, 2013 plaintiff served the summons and complaint to DTRS St. Francis, LLC, St. Francis Hotel Corporation (aka The Westin St. Francis), and Bourbon Steak. Plaintiff has not yet located Michael Judge for personal service.
3. On or about January 31, 2013 plaintiff's counsel was contacted by John Johnstone with Chubb Insurance and informed that the complaint incorrectly indentified the true names of the entities who owned and operated the St. Francis Hotel at the time of the alleged misconduct. Plaintiff's counsel was also provided with the name of local counsel to coordinate with regarding the amendment to the complaint and subsequent service, i.e., Heidi C. Quan, Murchison & Cummings, 275 Battery Street, Suite 550, San Francisco, CA 94111.
4. On February 19, 2013 plaintiff filed a First Amended Complaint (Document no. 11) and served the summons and complaint to attorney Heidi C. Quan, Murchison & Cummings, LLP via U.S. Mail on February 26, 2013.
5. Plaintiff's have yet to be contacted by anyone who represents Michael Judge and have not yet served him personally.
6. An order setting the initial case management conference and ADR deadlines was filed by the Court on December 18, 2013. These dates are as follows:
Meet and Confer re: initial disclosures, early
settlement, ADR process selection, and
discovery plan February 26, 2013
File ADR Certification signed by parties
and Counsel February 26, 2013
File either Stipulation to ADR Process or
Notice of Need for ADR Phone
Conference February 26, 2013
Last day to file Rule 26(f) Report,
Complete initial disclosures or state
objection in Rule 26(f) Report March 12, 2013
File Case Management Statement March 8, 2013
Initial Case Management Conference March 20, 2013
7. Based on the foregoing, counsel for plaintiff and defendants DTRS St. Francis, LLC, St. Francis Hotel Corporation (aks The Westin St. Francis) and Bourbon Street have agreed and propose to modify the Order setting the initial case management conference and ADR deadlines as follows:
Meet and Confer re: initial disclosures, early
settlement, ADR process selection, and
discovery plan May 3, 2013
File ADR Certification signed by parties
and Counsel May 3, 2013
File either Stipulation to ADR Process or
Notice of Need for ADR Phone
Conference May 3, 2013
Last day to file Rule 26(f) Report,
Complete initial disclosures or state
objection in Rule 26(f) Report May 22, 2013
File Case Management Statement May 17, 2013
Initial Case Management Conference May 29, 2013
IT IS SO STIPULATED.
[PROPOSED] ORDER
On the stipulation of the parties, and good cause appearing:
IT IS SO ORDERED.
