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.
§ CAUSE NO.3:06-CV-2325-O
DALLAS INDEPENDENT SCHOOL §
DISTRICT, et al., §
§
Defendants. §

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. Requested Relief

1. 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.
§ CAUSE NO.3:06-CV-2325-O
DALLAS INDEPENDENT SCHOOL §
DISTRICT, et al., §
§
Defendants. §

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