Opinion
NO. C10-03410 EMC
11-04-2011
TIMOTHY GARDNER, Plaintiff, v. CITY OF BERKELEY, DAVID HODGKINS; DOUG HAMBLETON; ROY MEISNER; BOBBY MILLER, Defendants.
ZACH COWAN, City Attorney MARK J. ZEMBSCH, Deputy City Attorney By MARK J. ZEMBSCH, Deputy City Attorney Attorneys for City of Berkeley and David Hodgkins Respectfully submitted: BURNS, SCHALDENBRAND & RODRIGUEZ By EDWARD W. BURNS Attorney for Plaintiff Timothy Gardner
ZACH COWAN, City Attorney
MARK J. ZEMBSCH, Deputy City Attorney
MZembsch@ci.berkeley.ca.us
2180 Milvia Street, Fourth Floor
Berkeley, CA 94704
TEL.: (510) 981-6998
FAX.: (510) 981-6960
Attorneys for Defendants
CITY OF BERKELEY and DAVID HODGKINS
EDWARD W. BURNS
MELISSA L. RODRIGUEZ
BURNS, SCHALDENBRAND & RODRIGUEZ
EWBurns@bsrlawyers.com
1155 Sportfisher Dr., Suite 120
Oceanside, CA 92045
TEL: (760) 453-2189
FAX: (760) 453-2194
Attorneys for Plaintiff
TIMOTHY GARDNER
STIPULATION AND [PROPOSED]
ORDER TO EXTEND EXPERT
DISCOVERY CUT-OFF
Complaint Filed: June 25, 2010
Removed to Federal Court: Aug. 3, 2010
STIPULATION
The parties hereby stipulate through their undersigned counsel that the expert discovery cut-off be extended as follows:
November 21, 2011: Expert's opening reports
December 5, 2011: Rebuttal reports
December 19, 2011: Expert discovery cut-off.
GOOD CAUSE EXISTS for the stipulation to extend time as follows: The Parties have one additional item of non-expert discovery remaining (the deposition of Eric Gustafson, scheduled for November 15, 2011). Thus, allowing the Parties a short period of time after non-expert discovery closes in order to complete expert discovery promotes the interests of justice and will result in no prejudice to any party.
Respectfully submitted:
ZACH COWAN, City Attorney
MARK J. ZEMBSCH, Deputy City Attorney
By MARK J. ZEMBSCH, Deputy City Attorney
Attorneys for City of Berkeley and David Hodgkins
Respectfully submitted:
BURNS, SCHALDENBRAND & RODRIGUEZ
By EDWARD W. BURNS
Attorney for Plaintiff Timothy Gardner
THE FOREGOING STIPULATION
IS APPROVED AND IS SO ORDERED.
Judge Edward M. Chen