Mckay V Disd
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Case 3:06-cv-02325-O
Document 96
Filed 12/19/2008
Page 1 of 3
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION GRACIELA SERNA McKAY Plaintiff, V. DALLAS INDEPENDENT SCHOOL DISTRICT, et al., Defendants.
§ § § § § § § § §
CAUSE NO.3:06-CV-2325-O
JOINT MOTION TO EXTEND MEDIATION DEADLINE TO THE HONORABLE COURT: Pursuant to Rules 6(b) and 29(b) of the Federal Rules of Civil Procedure, Plaintiff Graciela Serna McKay (“ Plaintiff” ) and Defendants Dallas Independent School District, Dallas Independent School District Board of Trustees, Dr. Michael Hinojosa, and Teresa Parker (collectively Defendants” ) submit this Joint Motion to Extend Mediation Deadline (“ Motion” ) and in support thereof respectfully show the Court as follows: I. 1.
Requested Relief
Plaintiff and Defendants jointly file this Motion to request extension of the
mediation deadline for the parties to properly mediate this case. The deadline to mediate is set for December 19, 2008.1 2.
The parties attempted to schedule mediation on several occasions during the
month of December. Due to several conflicts in the parties’schedule, however, mediation could not be scheduled by the deadline. Currently, the parties are seeking to mediate this case in the month of January because the current deadline of December 19, 2008 does not provide sufficient time to accommodate the schedules of the parties and the mediator. Thus, the parties seek to 1
Dkt. Entry No. 74.
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 1
Case 3:06-cv-02325-O
Document 96
Filed 12/19/2008
Page 2 of 3
extend the current mediation deadline to January 30, 2009. 3.
Nothing within this Motion and request will delay this proceeding or otherwise
interfere with this Court’ s docket. Plaintiff joins in this Motion and is in agreement with the requested relief. As such, Plaintiff and Defendants request that the deadline to mediate this case be extended to January 30, 2009. II.
Prayer
WHEREFORE, Plaintiff and Defendants request that the Court grant this Joint Motion for Extension of Deadline pursuant to Rule 6(b) and 29(b) of the Federal Rules of Civil Procedure. thereby extending the current mediation deadline until January 30, 2009. Respectfully submitted, GODWINRONQUILLO PC /s/ Ramona Soto_______________ Marcos G. Ronquillo State Bar No. 17226000 Jose L. Gonzalez State Bar No. 08129100 Kathryn E. Long State Bar No. 24041679 Ramona Soto State Bar No. 24051756 1201 Elm Street, Suite 1700 Dallas, Texas 75270-2041 214.939.4400 214.527.3124 –Facsimile ATTORNEYS FOR DEFENDANTS SANFORD & BETHUNE /s/ Brian P. Sanford_________________ Brian P. Sanford State Bar No. 17630700 3610 Shire Blvd. Richardson, Texas 75082 972.422.9435 972.644.8180 –Facsimile ATTORNEY FOR PLAINTIFF
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 2
Case 3:06-cv-02325-O
Document 96
Filed 12/19/2008
Page 3 of 3
CERTIFICATE OF CONFERENCE On December 19, 2008, counsel for Defendants conferred with counsel Plaintiff and Plaintiff’ s counsel did not oppose this motion.
CERTIFICATE OF SERVICE This is to certify that on December 19, 2008, this Motion was served on the following counsel electronically via the Court’ s ECF system: Brian P Sanford Sanford & Bethune 3610 Shire Blvd., Suite 206 Richardson, Texas 75082 /s/Ramona Soto Ramona Soto
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 3
Case 3:06-cv-02325-O
Document 96-2
Filed 12/19/2008
Page 1 of 1
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION GRACIELA SERNA McKAY Plaintiff, V. DALLAS INDEPENDENT SCHOOL DISTRICT, et al., Defendants.
§ § § § § § § § §
CAUSE NO.3:06-CV-2325-O
ORDER After considering Plaintiff’ s and Defendants’ Joint Motion to Extend Mediation Deadline, the Court is of the opinion that the motion should be and is hereby GRANTED. IT IS ORDERED that the mediation deadline shall be extended until January 30, 2009. SO ORDERED.
__________________ DATE
________________________________ Reed O’ Connor UNITED STATES DISTRICT JUDGE
Order
Document 96
Filed 12/19/2008
Page 1 of 3
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION GRACIELA SERNA McKAY Plaintiff, V. DALLAS INDEPENDENT SCHOOL DISTRICT, et al., Defendants.
§ § § § § § § § §
CAUSE NO.3:06-CV-2325-O
JOINT MOTION TO EXTEND MEDIATION DEADLINE TO THE HONORABLE COURT: Pursuant to Rules 6(b) and 29(b) of the Federal Rules of Civil Procedure, Plaintiff Graciela Serna McKay (“ Plaintiff” ) and Defendants Dallas Independent School District, Dallas Independent School District Board of Trustees, Dr. Michael Hinojosa, and Teresa Parker (collectively Defendants” ) submit this Joint Motion to Extend Mediation Deadline (“ Motion” ) and in support thereof respectfully show the Court as follows: I. 1.
Requested Relief
Plaintiff and Defendants jointly file this Motion to request extension of the
mediation deadline for the parties to properly mediate this case. The deadline to mediate is set for December 19, 2008.1 2.
The parties attempted to schedule mediation on several occasions during the
month of December. Due to several conflicts in the parties’schedule, however, mediation could not be scheduled by the deadline. Currently, the parties are seeking to mediate this case in the month of January because the current deadline of December 19, 2008 does not provide sufficient time to accommodate the schedules of the parties and the mediator. Thus, the parties seek to 1
Dkt. Entry No. 74.
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 1
Case 3:06-cv-02325-O
Document 96
Filed 12/19/2008
Page 2 of 3
extend the current mediation deadline to January 30, 2009. 3.
Nothing within this Motion and request will delay this proceeding or otherwise
interfere with this Court’ s docket. Plaintiff joins in this Motion and is in agreement with the requested relief. As such, Plaintiff and Defendants request that the deadline to mediate this case be extended to January 30, 2009. II.
Prayer
WHEREFORE, Plaintiff and Defendants request that the Court grant this Joint Motion for Extension of Deadline pursuant to Rule 6(b) and 29(b) of the Federal Rules of Civil Procedure. thereby extending the current mediation deadline until January 30, 2009. Respectfully submitted, GODWINRONQUILLO PC /s/ Ramona Soto_______________ Marcos G. Ronquillo State Bar No. 17226000 Jose L. Gonzalez State Bar No. 08129100 Kathryn E. Long State Bar No. 24041679 Ramona Soto State Bar No. 24051756 1201 Elm Street, Suite 1700 Dallas, Texas 75270-2041 214.939.4400 214.527.3124 –Facsimile ATTORNEYS FOR DEFENDANTS SANFORD & BETHUNE /s/ Brian P. Sanford_________________ Brian P. Sanford State Bar No. 17630700 3610 Shire Blvd. Richardson, Texas 75082 972.422.9435 972.644.8180 –Facsimile ATTORNEY FOR PLAINTIFF
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 2
Case 3:06-cv-02325-O
Document 96
Filed 12/19/2008
Page 3 of 3
CERTIFICATE OF CONFERENCE On December 19, 2008, counsel for Defendants conferred with counsel Plaintiff and Plaintiff’ s counsel did not oppose this motion.
CERTIFICATE OF SERVICE This is to certify that on December 19, 2008, this Motion was served on the following counsel electronically via the Court’ s ECF system: Brian P Sanford Sanford & Bethune 3610 Shire Blvd., Suite 206 Richardson, Texas 75082 /s/Ramona Soto Ramona Soto
JOINT MOTION TO EXTEND MEDIATION DEADLINE –Page 3
Case 3:06-cv-02325-O
Document 96-2
Filed 12/19/2008
Page 1 of 1
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION GRACIELA SERNA McKAY Plaintiff, V. DALLAS INDEPENDENT SCHOOL DISTRICT, et al., Defendants.
§ § § § § § § § §
CAUSE NO.3:06-CV-2325-O
ORDER After considering Plaintiff’ s and Defendants’ Joint Motion to Extend Mediation Deadline, the Court is of the opinion that the motion should be and is hereby GRANTED. IT IS ORDERED that the mediation deadline shall be extended until January 30, 2009. SO ORDERED.
__________________ DATE
________________________________ Reed O’ Connor UNITED STATES DISTRICT JUDGE
Order
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