Opinion
MELINDA HAAG, United States Attorney, ALEX G. TSE, Chief, Civil Division, MICHELLE LO, Assistant United States Attorney, San Francisco, California, Attorneys for the United States of America.
SUSAN M. BENSON, Susan M. Benson & Associates, LLP, Encino, California, Attorney for Plaintiff.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE AND JOINT STATUS REPORT DEADLINE
SAMUEL CONTI, District Judge.
Plaintiff, Farmers Insurance Exchange, and Defendant, the United States of America, by and through their undersigned attorneys, hereby stipulate as follows:
1. At the initial case management conference held on March 7, 2014, the Court directed the parties to file a stipulation and proposed order for mediation once they agreed on a potential mediator. The parties held phone conferences with the ADR Program Legal Staff on April 7, 2014, and June 10, 2014. Due to a procedural misunderstanding, however, the parties did not file their stipulation and proposed order for mediation until today, June 11, 2014. See ECF No. 26.
2. At the March 7, 2014, initial case management conference, the Court also set a further status conference for Friday, June 20, 2014, at 10 a.m., and ordered the parties to file an updated status report by June 13, 2014. ECF No. 31.
3. Because the parties have not had an opportunity to engage in the ADR process to date, they have requested a period of 90 days in which to schedule mediation and conduct limited discovery to facilitate meaningful discussions. In light of these circumstances, the parties respectfully request that the Court continue the status conference scheduled for June 20, 2014, to September 26, 2014, or such later date as the Court's calendar permits.
4. The parties will work in good faith to mediate the case prior to a further status conference on September 26, 2014, or such later date as the Court may set.
5. Accordingly, the parties hereby agree and stipulate to a continuance of the status conference scheduled to September 26, 2014, and the related joint status report deadline to September 19, 2014, or such later date as the Court may set, and request that the Court order the same.
SO STIPULATED.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The further status conference scheduled for June 20, 2014, at 10 a.m. is continued to September 26, November 14, 2014, at 10 a.m. The parties shall file a joint status report at least seven days prior to the conference.