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JOINT MOTION TO EXTEND MEDIATION DEADLINE
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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF TEXASDALLAS DIVISIONGRACIELA SERNA McKAYPlaintiff,V.DALLAS INDEPENDENT SCHOOLDISTRICT, et al.,Defendants.
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CAUSE NO.3:06-CV-2325-OJOINT MOTION TO EXTEND MEDIATION DEADLINETO THE HONORABLE COURT:
Pursuant to Rules 6(b) and 29(b) of the Federal Rules of Civil Procedure, Plaintiff Graciela Serna McKay (
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Plaintiff
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) and Defendants Dallas Independent School District, DallasIndependent School District Board of Trustees, Dr. Michael Hinojosa, and Teresa Parker(collectively Defendants
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) submit this Joint Motion to Extend Mediation Deadline (
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Motion
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)and in support thereof respectfully show the Court as follows:I.
Requested Relief
1.Plaintiff and Defendants jointly file this Motion to request extension of themediation deadline for the parties to properly mediate this case.Thedeadline to mediate is setfor December 19, 2008.
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2.The parties attempted to schedule mediation on several occasions during themonth of December. Due to several conflicts in the parties
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schedule, however, mediation couldnot be scheduled by the deadline. Currently, the parties are seeking to mediate this case in themonth of January because the current deadline of December 19, 2008 does not provide sufficienttime to accommodate the schedules of the parties and the mediator. Thus, the parties seek to
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Dkt. Entry No. 74.
Case 3:06-cv-02325-O Document 96 Filed 12/19/2008 Page 1 of 3
JOINT MOTION TO EXTEND MEDIATION DEADLINE
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extend the current mediation deadline to January 30, 2009.3.Nothing within this Motion and request will delay this proceeding or otherwiseinterfere with this Court
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s docket. Plaintiff joins in this Motion and is in agreement with therequested relief. As such, Plaintiff and Defendants request that the deadline to mediate this casebe extended to January 30, 2009.II.
Prayer
WHEREFORE, Plaintiff and Defendants request that the Court grant this Joint Motionfor Extension of Deadline pursuant to Rule 6(b) and 29(b) of the Federal Rules of CivilProcedure. thereby extending the current mediation deadline until January 30, 2009.
Respectfully submitted,
GODWINRONQUILLO PC
/s/ Ramona Soto_______________Marcos G. RonquilloState Bar No. 17226000Jose L. GonzalezState Bar No. 08129100Kathryn E. LongState Bar No. 24041679Ramona SotoState Bar No. 240517561201 Elm Street, Suite 1700Dallas, Texas 75270-2041214.939.4400214.527.3124
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Facsimile
ATTORNEYS FOR DEFENDANTSSANFORD & BETHUNE
/s/ Brian P. Sanford_________________Brian P. SanfordState Bar No. 176307003610Shire Blvd.Richardson, Texas 75082972.422.9435972.644.8180
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Facsimile
ATTORNEY FOR PLAINTIFF
Case 3:06-cv-02325-O Document 96 Filed 12/19/2008 Page 2 of 3
JOINT MOTION TO EXTEND MEDIATION DEADLINE
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CERTIFICATE OF CONFERENCE
On December 19, 2008, counsel for Defendants conferred with counsel Plaintiff andPlaintiff
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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 followingcounsel electronically via the Court
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s ECF system:Brian P SanfordSanford & Bethune3610Shire Blvd., Suite 206Richardson, Texas 75082 /s/Ramona SotoRamona Soto
Case 3:06-cv-02325-O Document 96 Filed 12/19/2008 Page 3 of 3
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