Filed: May 20, 2014
Latest Update: May 20, 2014
Summary: JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR MANDATORY SETTLEMENT CONFERENCE MAXINE M. CHESNEY, District Judge. Plaintiff, Robert Verdina ("Plaintiff'), and Defendants CVS CAREMARK CORPORATION, CVS RX SERVICES, AMRIT VIRDEE, and RUI CAMACHO ("Defendants"), file this Joint Stipulated Request to extend the date for Mandatory Settlement Conference from May 29, 2014 to July 10, 2014, or as soon thereafter as the court be available. As grounds for this Motion, the Part
Summary: JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR MANDATORY SETTLEMENT CONFERENCE MAXINE M. CHESNEY, District Judge. Plaintiff, Robert Verdina ("Plaintiff'), and Defendants CVS CAREMARK CORPORATION, CVS RX SERVICES, AMRIT VIRDEE, and RUI CAMACHO ("Defendants"), file this Joint Stipulated Request to extend the date for Mandatory Settlement Conference from May 29, 2014 to July 10, 2014, or as soon thereafter as the court be available. As grounds for this Motion, the Parti..
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JOINT STIPULATED REQUEST AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR MANDATORY SETTLEMENT CONFERENCE
MAXINE M. CHESNEY, District Judge.
Plaintiff, Robert Verdina ("Plaintiff'), and Defendants CVS CAREMARK CORPORATION, CVS RX SERVICES, AMRIT VIRDEE, and RUI CAMACHO ("Defendants"), file this Joint Stipulated Request to extend the date for Mandatory Settlement Conference from May 29, 2014 to July 10, 2014, or as soon thereafter as the court be available. As grounds for this Motion, the Parties state:
1. Littler Mendelson, P.C. began representing CVS in this manner on February 14, 2014.
2. The two named individual defendants, Rui Camacho and Amritpa1 Virdee, made their first appearance in this case on May 6, 2014.
3. Pursuant to the January 10, 2014 Ci'vil Pretrial Minutes, the case was "referred to Magistrate Judge Nathaneal Cousins for a Settlement Conference, to be conducted in late in late May or early June — his calendar permitting." Pursuant to the Court's January 14, 2014 Order Setting Settlement Conference, the date set for the Mandatory Settlement Conference is currently May 29, 2014.
4. Counsel for the parties agree that settlement discussions would be premature and very likely unsuccessful prior to the deposition of all named parties.
5. Plaintiff and CVS have engaged in good faith discovery efforts and have completed one round of written discovery. The Parties require additional time to conduct depositions of one of the named individual defendants and the plaintiff.
6. The Parties anticipate that they will not be able to complete the pending depositions by the current settlement conference date because of the challenges associated with, and additional time needed for, coordinating the deposition of one named defendant among counsel and the witness' schedules prior to May 29, 2014.
7. The Parties have met and conferred and agree that they would be available on July 10, 2014 to conduct the Mandatory Settlement Conference. The Parties have checked with Magistrate Judge Cousins' clerk and are of the infonnation and belief that this date is agreeable to Magistrate Judge Cousins as well.
8. Accordingly, the Parties respectfully request that the Court reschedule the Mandatory Settlement Conference from May 29,2014 to July 10, 2014, or as soon thereafter as is practicable.
9. Neither Party will be prejudiced by the extension of this date. Both Parties will, however, be prejudiced if the Court denies this Motion and prevents them from conducting the pending depositions to develop the factual record in this case.
WHEREFORE, the Parties respectfully request that the Court extend the current deadline to conduct a settlement conference as set forth above.
IT IS SO ORDERED.
