Free Letter - District Court of California - California

Case 5:08-cv-00248-PVT

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WILLOUGHBY. STUART & BENING
A PROFESSIONAL LAW CORPORATION FAIRMONT PLAZA
50 WEST StlN FERNANDO. SUITE 4IJO
StlN JOSE. CtlUFORNIA 95113 TELEPHONE (408) 289-1972

[email protected]

FACSIMILE (408) 295-6375

May 16,2008 The Honorable Patricia V. Trumbull United States District Court- Northern 280 S. First Street, Dept. 5 San Jose, CA 95113 RE: Finley v. Pulcrano, et al. Our File: 1806.10811 B

Dear Judge: The parties have attempted to meet and confer about selecting a Mediator. Defendants initiated discussion regarding Alternative Dispute Resolution and plaintiff has yet to respond despite assuring that they would do so as requested by the court. ( See Exhibits 1 and 2) The parties in light of this unforeseen delay respectfully request an additional week to infonn the court of their decision regarding Alternative Dispute Resolution. Very truly yours, WILLOUGHBY, STUART & BENING Dictated but not read to avoid delay. George W. Dowell GWD:dal Enclosure

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EXHIBIT

J


Case 5:08-cv-00248-PVT
George Dowell
From: Sent: To: Cc: Subject:

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George Dowell Tuesday, May 13, 20082:56 PM 'Miguel Rodriguez' Brad Bening; '[email protected]' Finley v. Pulcrano Mediation

Miguel, In order to move the mediation selection along I am providing you with the information of two mediators that we believe would be effective in resolving this matter. 1) 2) Hon. Len Sprinkles, Ret. with Mediation Masters. http://www.mediationmasters.com/sprinkles.htm Hon. John Flaherty, Ret. with JAMS. http://www.jamsadr.com/Neutrals/Bio.asp?NeutraIID=1633

Let us know which of these candidates would be preferable to you, or please offer the name of any other neutral that would like for us consider. At this time we would strongly prefer to pursue a private mediation. Once we have decided on a mediator, we can address the timeframe we would like to pursue in having the mediation take place. George George W. Dowell, Esq. Willoughby, Stuart & Bening Inc. 50 W. San Fernando Street Suite 400 San Jose, CA 95113 Tel: 408.289.1972 Fax: 408.295.6375

Case 5:08-cv-00248-PVT

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EXHIBIT if

Case 5:08-cv-00248-PVT
George Dowell
From: Sent: To:

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Cc:
Subject:

Miguel Rodriguez [[email protected]] Tuesday, May 13, 2008 3:06 PM George Dowell Brad Bening; [email protected] RE: Finley v. Pulcrano Mediation

I'll get back to you tomorrow or Thursday on these mediators Also, I have my signature and my client's signature on the confidentiality agreement. Please let me know when your and your clients' signatures are ready too and we can exchange. Miguel

From: George Dowell [mailto:[email protected]] Sent: Tuesday, May 13, 2008 4:56 PM To: Miguel Rodriguez Cc: Brad Bening; [email protected] Subject: Finley v. Pulcrano Mediation

Miguel, In order to move the mediation selection along I am providing you with the information of two mediators that we believe would be effective in resolving this matter.

1) 2)

Hon. Len Sprinkles, Ret. with Mediation Masters. http://www.mediationmasters.com/sprinkles.htm Hon. John Flaherty, Ret. with JAMS. http://www.jamsadr.com/Neutrals/Bio.asp?NeutraIlD=1633

Let us know which of these candidates would be preferable to you, or please offer the name of any other neutral that would like for us consider. At this time we would strongly prefer to pursue a private mediation. Once we have decided on a mediator, we can address the timeframe we would like to pursue in having the mediation take place. George George W. Dowell, Esq. Willoughby, Stuart & Bening Inc. 50 W. San Fernando Street Suite 400 San Jose, CA 95113 Tel: 408.289.1972 Fax: 408295.6375

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