Opinion
Case No. CV-10-05097 PSG
10-13-2011
Ely Bartolo, Plaintiff, v. Elvira B. Cardona, Rodolfo Cardona, Monte Farley Manor, Does 1-30 Defendants.
LAW OFFICES OF RAFAEL CRESPO, JR. RAFAEL CRESPO, JR. Attorney for Plaintiff Ely Bartolo LOSCH & EHRLICH Ronald K. Losch, Esq. Attorney for Defendants Elvira B. Cardona, Rodolfo Cardona, and Monte Farley Manor
RAFAEL CRESPO, JR., ESQ.
LAW OFFICES OF RAFAEL CRESPO, JR.
Attorney for Plaintiff,
Ely Bartolo
STIPULATION AND REQUEST FOR
ORDER TO CONTINUE MEDIATION DEADLINE
NOW COME THE PARTIES TO THIS CASE AND STIPULATE AS FOLLOWS:
1. Plaintiff and all Defendants agree to extend the May 2, 2011 deadline to participate in mediation to a date mutually agreeable to all parties but no later than October 31, 2011; the parties have, moreover, agreed to schedule the mediation on October 18, 2011.
2. The basis for this stipulation to continue the present mediation deadline is that plaintiff Ely Bartolo moved from her home without informing Plaintiff's counsel. This occurred when the parties were trying to schedule the mediation. Moreover, plaintiff does not have a telephone number. Plaintiff's counsel was, therefore, unable to locate Ms. Bartolo to advise her of said mediation.
3. The parties, therefore, respectfully request that the court extend the deadline to participate in mediation to October 31, 2011. Plaintiff counsel has contacted defense counsel and the mediator John DiNapoli have tentatively arranged a new date for the mediation.
SO STIPULATED:
LAW OFFICES OF RAFAEL CRESPO, JR.
RAFAEL CRESPO, JR.
Attorney for Plaintiff
Ely Bartolo
LOSCH & EHRLICH
Ronald K. Losch, Esq.
Attorney for Defendants
Elvira B. Cardona, Rodolfo Cardona, and
Monte Farley Manor
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Paul Singh Grewal
United States Magistrate Judge
PROOF OF SERVICE
I, STAN CRESPO, declare that:
I am a citizen of the United States and am employed in the County of San Francisco, State of California. My business address is 354 Pine Street, 3rd.Fl., San Francisco, CA 94104. I am over the age of 18 years and not a party to the within cause.
I am readily familiar with my employer's business practice for collection and processing of correspondence for mailing with the United States Postal Office. On October 11, 2011,1 caused to be served: PLAINTIFF ELY BARTOLO'S STIPULATION AND REQUEST FOR ORDER TO CONTINUE MEDIATION DEADLINE on:
Ron Losh, Esq.
Losch & Ehrlich
Attorneys-at- Law
425 California Street, Suite 2025
San Francisco, CA 94104
[X] (BY MAIL) In a sealed envelope with postage thereon fully prepaid, I deposited such envelope in the United States mail at San Francisco, California for the office of the addressee above. (CCP section 1010)
[] (BY PERSONAL SERVICE) I caused such envelope(s) to be delivered by hand this date to the office of the addressee(s).
[] (BY FACSIMILE) I caused the said document(s) to be transmitted by facsimile machine to the number indicated after the address (es) noted above.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October 11, 2011 at San Francisco, California.
By: STAN CRESPO