Opinion
No. C10-03703 SI (ADR)
10-24-2011
NADRA FOSTER, Plaintiff, v. BERKELEY POLICE DEPARTMENT; et al., Defendants.
ZACH COWAN, City Attorney MATTHEW J. OREBIC, Deputy City Attorney LYNNE S. BOURGAULT, Deputy City Attorney MATTHEW J. OREBIC Attorneys for Defendants CITY OF BERKELEY, , DOUGLAS HAMBLETON, ALEXANDER McDOUGALL and ERIK KEENE ARCOLINA PANTO Attorney for Plaintiff NADRA FOSTER NGO LEGAL GROUP, A Professional Corp. STEVE NGO Attorney for Defendants LOIS WITHERS, KPFA, and PACIFICA FOUNDATION PURSUANT TO STIPULATION, IT IS SO ORDERED.
Zach Cowan, City Attorney, SBN 96372
Matthew J. Orebic, Deputy City Attorney, SBN 124491
Lynne S. Bourgault, Deputy City Attorney, SBN 180416
BERKELEY CITY ATTORNEY'S OFFICE
Attorneys for Defendants
CITY OF BERKELEY, DOUGLAS HAMBLETON,
ALEXANDER McDOUGALL and ERIK KEENE
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DEPOSITION
OF DR. LISA LATTANZA BEYOND THE
DISCOVERY CUT-OFF
The parties through their counsel herein stipulate that the deposition of Dr. Lisa Lattanza, a treating doctor for plaintiff, currently set for October 25, 2011 at 4:00 p.m. at UCSF Medical Center, 1500 Owens Street, First Floor, San Francisco, CA can be continued to November 22, 2011 at 4:00 p.m. at the same location. The non-expert discovery cutoff is October 28, 2011. Defense counsel for City of Berkeley, Matthew Orebic, requests this continuance of the deposition to a date beyond the percipient witness discovery cutoff because (1) Mr. Orebic is needed at a medical procedure for his 88-year old mother that was recently scheduled on an expedited basis, (2) there is no other person or family member as appropriate as Mr. Orebic to transport and care for his mother on October 25, and (3) the next available date for Dr. Lattanza to give a deposition is November 22. Plaintiff's counsel is concerned that parties do not have the authority to make such a stipulation, but is amenable due to human concerns.
Respectfully submitted:
ZACH COWAN, City Attorney
MATTHEW J. OREBIC, Deputy City Attorney
LYNNE S. BOURGAULT, Deputy City Attorney
MATTHEW J. OREBIC
Attorneys for Defendants
CITY OF BERKELEY, , DOUGLAS
HAMBLETON, ALEXANDER McDOUGALL
and ERIK KEENE
Respectfully submitted:
ARCOLINA PANTO
Attorney for Plaintiff
NADRA FOSTER
Respectfully submitted:
NGO LEGAL GROUP, A Professional Corp.
STEVE NGO
Attorney for Defendants
LOIS WITHERS, KPFA, and PACIFICA
FOUNDATION
PURSUANT TO STIPULATION, IT IS SO ORDERED.
HONORABLE SUSAN ILLSTON
Judge of the U.S. District Court