Stipulation and Proposed Order Continuing Date to Complete Mediation CV090114MMC

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Eugene B. Elliot, State Bar No. 111475

Christine Lee, State Bar No. 231617

BERTRAND, FOX & ELLIOT

The Waterfront Building

2749 Hyde Street

San Francisco, California 94109

Telephone: (415) 353-0999

Facsimile: (415) 353-0990

Attorneys for Defendants SONOMA COUNTY JUNIOR COLLEGE DISTRICT,

erroneously also named as Santa Rosa Junior College and STEVE COHEN

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

JOANNE FUSCO, an individual,

Plaintiff,

vs.

SONOMA COUNTY JUNIOR COLLEGE

DISTRICT; SANTA ROSA JUNIOR

COLLEGE SONOMA COUNTY JUNIOR

COLLEGE DISTRICT; and STEVE COHEN,

Defendants.

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Case No.: CV09-0114 MMC

STIPULATION AND [PROPOSED] ORDER

CONTINUING DATE TO COMPLETE

MEDIATION FROM JULY 1, 2010 TO

AUGUST 20, 2010

Plaintiff JOANNE FUSCO and defendants SONOMA COUNTY JUNIOR COLLEGE

DISTRICT and STEVE COHEN, acting by and through their respective legal counsel, hereby

stipulate to continue the date to complete mediation from July 1, 2010 to August 20, 2010.

Good cause exists for this stipulation because both parties need time to conduct the necessary

discovery before they can participate in a meaningful mediation. Plaintiff’s deposition took place on

May 11, 2010, but both parties agree that further deposition is necessary and have agreed to continue

the deposition on June 15, 2010. The deposition is set in June to allow time for the parties to agree

on a protective order for the production of plaintiff’s psychological records, as plaintiff has claimed

psychological treatment as part of her damages. The parties have been meeting and conferring in

good faith about the production of plaintiff’s psychological records and are close to agreeing about

the scope of the protective order. Also, plaintiff is expected to produce responses to written

Case 3:09-cv-00114-MMC Document 56 Filed 05/28/10 Page 1 of 3
Stipulation and Proposed Order Continuing Date to Complete Mediation CV090114MMC

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discovery on June 8, 2010, after the DISTRICT agreed to a three-week extension for the responses.

A new mediation date has been tentatively scheduled for July 28, 2010, contingent upon the

approval of the court.

SO STIPULATED.

Dated: May 26, 2010 BERTRAND, FOX & ELLIOT

By: /S/

Eugene B. Elliot

Christine Lee

Attorneys for Defendants SONOMA COUNTY

JUNIOR COLLEGE DISTRICT and STEVE COHEN

Dated: May 26, 2010 TOWNER LAW OFFICES

By: /S/

BRUCE M. TOWNER

Attorney for Plaintiff

Joanne Fusco

ATTORNEY ATTESTATION

I hereby attest that I have on file all holograph signatures for any signatures indicated by a

“conformed” signature (/s/) within this E-filed document.

Dated: May 26, 2010 /S/

Eugene B. Elliot

Case 3:09-cv-00114-MMC Document 56 Filed 05/28/10 Page 2 of 3
Stipulation and Proposed Order Continuing Date to Complete Mediation CV090114MMC

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ORDER

GOOD CAUSE APPEARING THEREFORE, the stipulation to continue the date to complete

mediation from July 1, 2010 to August 20, 2010 is GRANTED.

Dated: ____________________ ______________________________________

The Honorable Maxine M. Chesney

May 28, 2010

Case 3:09-cv-00114-MMC Document 56 Filed 05/28/10 Page 3 of 3