Peilin Chang v. American Airlines, Inc.

Northern District of California, cand-4:2015-cv-02604

STIPULATION AND ORDER EXTENDING TIME TO COMPLETE MEDIATION, granting {{26}}. The deadline to conduct private mediation is extended from 8/31/2016 to 11/18/2016. 2/2/2017 Pretrial Conference and 2/21/2017 Jury Trial to remain as presently set. Signed by Hon. Ronald M. Whyte on 8/29/2016.

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1 TIMOTHY J. RYAN, SBN 99542 REBEKKA R. MARTORANO, SBN 173600 2 THE RYAN LAW GROUP 400 Capitol Mall, Suite 2540 3 Sacramento, California 95814 Telephone: (916) 924-1912 4 Facsimile: (916) 923-3872 tryan@ryanlg.com 5 rmartorano@ryanlg.com 6 Attorneys for Defendant American Airlines, Inc. 7 UNITED STATES DISTRICT COURT 8 NORTHERN DISTRICT OF CALIFORNIA 9 SAN JOSE DIVISION 10 11 PEILIN CHANG) Case No. 15-cv-02604-RMW) 12 Plaintiff,)) STIPULATION AND ORDER 13 v.) EXTENDING TIME TO COMPLETE) MEDIATION 14 AMERICAN AIRLINES, INC.,)) 15 Defendant.) Judge: Honorable Ronald M. Whyte) Courtroom: 6, 4th Floor 16) ____________________________________) 17 18 19 The parties in the above-captioned matter hereby stipulate as follows: 20 1. WHEREAS the current scheduling order of April 14, 2016 provides for a deadline to 21 complete private mediation of August 31, 2016. 22 2. WHEREAS the parties have been diligently engaged in discovery, including the following: 23 a. Arranging for two defense medical examinations of plaintiff: a neurological 24 examination that was completed on July 11, 2016 and a neuropsychological 25 examination to be conducted on August 30, 2016; 26 b. Completing depositions of plaintiff (7/11/16), plaintiff's treating physician Dr. Rosen 27 (7/29/16), employees of plaintiff's medical practice (8/19/16 and 8/22/16), and 28 bookkeepers and accountants for plaintiff's medical practice (8/18/16, 8/19/16 and 1 STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION 1 8/22/16); 2 c. Scheduling additional depositions, including the deposition of plaintiff's neurologist, 3 Dr. Helman (originally scheduled on 8/22/16 but continued to 9/20/16 at the request 4 of the witness), and plaintiff's colleague, Dr. Lubben (9/9/16); 5 d. Conferring regarding additional depositions to be set, including the flight attendant 6 involved in the subject incident. 7 3. Notwithstanding the parties' diligent efforts, the case is not yet ripe for mediation. Plaintiff 8 alleges that she has sustained significant and permanent injuries and a significant loss of 9 income. These claims require further investigation before a meaningful mediation can be 10 conducted. 11 4. Therefore the parties propose that the deadline to conduct private mediation be extended by 12 approximately 80 days, from August 31, 2016 to November 18, 2016. 13 14 IT IS SO STIPULATED. 15 16 Dated: August 26, 2016 BROWNSTEIN THOMAS, LLP 17 18 By: /s/ Stephen Gorog STEPHEN GOROG 19 Attorneys for plaintiff Peilin Chang 20 21 Dated: August 26, 2016 THE RYAN LAW GROUP 22 23 By: /s/ Rebekka Martorano REBEKKA R. MARTORANO 24 Attorneys for Defendant American Airlines, Inc. 25 26 27 28 2 STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION 1 ORDER 2 Based on the stipulation of the parties and good cause appearing, IT IS HEREBY ORDERED 3 that the deadline to conduct private mediation is extended from August 31, 2016 to November 18, 4 2016. 2/2/2017 Pretrial Conference and 2/21/2017 Jury Trial to remain as presently set. 5 6 IT IS SO ORDERED. 7 8 Dated:______________________ 8/29/2016 ______________________________ Judge, United States District Court 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION AND ORDER EXTENDING TIM E TO COM PLETE M EDIATION