Opinion
Case No. C11-02195 PJH
11-07-2011
DAMALI CARTER, an individual, Plaintiff, v. FOOTLOCKER, INC., a New York Corporation, and DOES 1-50, Defendant.
Mark C. Thomas Brownstein Thomas, LLP Attorney for Plaintiff DAMALI CARTER Gabrielle Handler Marks (SBN: 203733) SHOOK, HARDY & BACON, LLP William C. Martucci (Admitted Pro Hac Vice ) Kristen A. Page (Admitted Pro Hac Vice ) SHOOK, HARDY & BACON, LLP Attorneys for Defendant FOOT LOCKER, INC.
Mark C. Thomas
Brownstein Thomas, LLP
Attorney for Plaintiff
DAMALI CARTER
Gabrielle Handler Marks (SBN: 203733)
SHOOK, HARDY & BACON, LLP
William C. Martucci (Admitted Pro Hac Vice)
Kristen A. Page (Admitted Pro Hac Vice)
SHOOK, HARDY & BACON, LLP
Attorneys for Defendant
FOOT LOCKER, INC.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE MEDIATION COMPLETION DATE
Plaintiff Demali Carter and Defendant Foot Locker, Inc. (collectively the "Parties"), by and through their respective attorneys of record, and hereby respectfully submit this Stipulation and [Proposed] Order to Continue the Mediation Completion Date in connection with the above-captioned action.
The Court ordered the Parties to complete Mediation on or before October 31, 2011. The Parties agreed to exchange written discovery and take one deposition per side prior to the mediation. The Parties completed the exchange of written discovery but have not been able to complete the one deposition per side due to the travel schedule of witnesses and counsel. The Parties believe the completion of the depositions is needed to facilitate the mediation. The Parties and the mediator ArrnaMary Gannon are available and have agreed to conduct the mediation on January 11, 2012. There have not been any other continuances of the mediation completion date. The Parties believe the requested continuance of the date for completion of the mediation will have no appreciable effect on the schedule of the action (See Local Rule 6-2(a)).
ACCORDINGLY, the Parties, by and through their respective counsel of record, with approval of the Mediator, Ms. AnnaMary Gannon, hereby stipulate to a continuance of the mediation and mediation completion date until January 11, 2012.
Respectfully submitted by:
FOR PLAINTIFF
Mark C. Thomas
Brownstein Thomas, LLP
180 Montgomery Street, Suite 940
San Francisco, California 90010
T: (415)986-1338
FOR DEFENDANT
Gabrielle Handler Marks (SBN 203733)
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2700
San Francisco, California 94104-2828
Telephone: (415)544-1900
Fax: (415)391-0281
gmarks@shb.com
and
William C. Martucci (admitted pro hac vice)
Kristen A. Page (admitted pro hac vice)
SHOOK, HARDY & BACON L.L.P.
2555 Grand Boulevard
Kansas City, Missouri 64108
Telephone: (816)474-6550
Fax: (816)421-5547
wmartucci @shb.com
kpage@shb.com
[PROPOSED] ORDER
Upon review of this Stipulation and [Proposed] Order to Continue Mediation Completion Date and good cause appearing:
IT IS HEREBY ORDERED that the Mediation Completion Date in the above-reference action is hereby continued to January 11, 2012.
Judge Phyllis J. Hamilton