Opinion
MICHAEL J. HADDAD (State Bar No. 189114), JULIA SHERWIN (State Bar No. 189268), GINA ALTOMARE (State Bar No. 273099), GENEVIEVE K. GUERTIN (State Bar No. 262479), HADDAD & SHERWIN, Oakland, California Attorneys for Plaintiffs JAIME REYES, JR., MIRELLA REYES and JAIME REYES, SR.
MANNING & KASS, ELLROD, RAMIREZ, TRESTER, LLP MILDRED K. O'LINN, TONY M. SAIN, Attorneys for Defendants.
STIPULATION AND ORDER TO AMEND CASE MANAGEMENT ORDER
SHEILA K. OBERTO, Magistrate Judge.
ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE, AND REQUEST THIS COURT TO ORDER, THAT the case management order be amended as follows:
This is a complex wrongful-death civil rights case with 4 named Defendants and 8 remaining Doe Defendants. The parties have exchanged initial disclosures, exchanged some written discovery and produced some documents and records. The parties have met and conferred, and will continue to do so, regarding additional document production. The parties are in the process of scheduling the depositions of the two named individual Defendants, as well as of Plaintiffs and multiple witnesses for dates beginning in late-January.
Plaintiffs served their request for production of documents on Defendants on June 7, 2013. The parties have met and conferred extensively regarding document production and have agreed on a production date of January 10, 2014.
Due to the need for additional time for document production, as well as the number of Defendants and witnesses who must still be deposed, the parties anticipate that discovery will not be complete by the current deadline of February 14, 2014. The parties, therefore, stipulate to continue the deadlines for the completion of fact discovery and expert disclosures from February 14, 2014 to March 14, 2014. This is the first request for extension of such deadlines.
Therefore, the parties respectfully request that this Court continue the current deadlines in this matter as follows:
Deadline Description Current Deadline/Date Proposed Modified Deadline/Date Completion of Non-Expert February 14, 2014 March 14, 2014 Discovery Disclosure of Expert Witnesses' February 14, 2014 March 14, 2014 Identities and Reports
Disclosure of Rebuttal Expert February 28, 2014 March 28, 2014 Witnesses Dispositive Motion Hearing July 9, 2014 No change Deadline Settlement Conference April 3, 2014, 10:00 a.m. No change Completion of Expert Discovery April 18, 2014 No change Pretrial Conference August 20, 2014 No change Trial October 7, 2014 No change
Additionally, due to the aforementioned circumstances, the parties also stipulate that Plaintiffs shall have until February 17, 2014 to amend their Complaint for the purpose of naming Doe Defendants only. This stipulation extends the current deadline of December 20, 2013. Other than for the purposes of naming Doe Defendants, nothing in this Stipulation, nor any associated Order, shall be construed so as to modify or otherwise extend the deadline for amendment of pleadings in any other regard beyond the previous October 31, 2013 deadline.
ORDER
Pursuant to stipulation of the parties and good cause appearing, IT IS SO ORDERED.