Opinion
Case No. CV 12-1944 JST
03-28-2013
SONYA KNUDSEN, Plaintiff, v. CITY AND COUNTY OF SAN FRANCISCO, SAN FRANCISCO INTERNATIONAL AIRPORT, JOHN MARTIN, BLAKE SUMMERS, AND DOES 1 THROUGH 25, INCLUSIVE, Defendants.
DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH SALVESON, State Bar #83788 Chief Labor Attorney LISA B. BERKOWITZ, State Bar #167657 Deputy City Attorney Fox Plaza Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO, JOHN MARTIN and BLAKE SUMMERS
DENNIS J. HERRERA, State Bar #139669
City Attorney
ELIZABETH SALVESON, State Bar #83788
Chief Labor Attorney
LISA B. BERKOWITZ, State Bar #167657
Deputy City Attorney
Fox Plaza
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO,
JOHN MARTIN and BLAKE SUMMERS
STIPULATION AND PROPOSED ORDER
CHANGING DEADLINES IN PRETRIAL
PREPARATION ORDER
[Civil L.R., Rule 6-2; 7-12]
Plaintiff Sonya Knudsen and Defendants City and County of San Francisco ("City"), John Martin, and Blake Summers hereby submit the following Stipulation and Proposed Order continuing pretrial deadlines in the above-referenced case, pursuant to Northern District Civil L.R., Rules 6-2 and 7-12. Per Rule 6-2(a):
(1) The parties seek to continue these dates for the following reasons: Plaintiff filed an Amended Complaint on January 25, 2013, adding three new causes of action: gender discrimination; disability discrimination; and retaliation under the Fair Employment and Housing Act. The parties request additional time to conduct discovery on these claims. Furthermore, the parties agreed to withhold taking City witness depositions while they explored whether early settlement was possible. Unfortunately, it was not. Finally, Plaintiff's counsel will be out of the office for the first three weeks of June 2013 on vacation. The City's counsel is going on maternity leave beginning on or around June 6, 2013. The short two month extension on the dates below will give the new Deputy City Attorney assigned to the case a chance to transition into this case and prepare the City's anticipated motion for summary judgment.
(2) There have been no previous time modifications in the case.
(3) Since this Court has vacated the current trial date of September 16, 2013, it is not anticipated that the requested time modification will adversely impact the schedule of this case. For the Court's information, the parties intend to propose a trial date of November 18, 2013 in their Joint Case Management Conference Statement, which the Court has ordered filed by May 20, 2013. The parties believe the dates below would be appropriate for a November 2013 (or later) trial date.
Accordingly, the parties stipulate to the following time modifications on Judge Illston's August 8, 2012 Pretrial Preparation Order:
Non-Expert Discovery Cutoff:
Existing Date: May 10, 2013
New Date: July 9, 2013
Designation of Experts:
Existing Date: June 7, 2013
New Date: August 7, 2013
Dispositive Motions Shall be Filed by:
Existing Date: June 14, 2013
Opposition Due: June 28, 2013
Reply Due: July 5, 2013.
New Date: August 16, 2013
Opposition Due: August 30, 2013
Reply Due: September 6, 2013
______________________
JOHN HOUSTON SCOTT, Esq.
Scott Law Firm
Attorney for Plaintiff
SONYA KNUDSEN
______________________
DENNIS J. HERRERA
City Attorney
ELIZABETH S. SALVESON
Chief Labor Attorney
LISA BERKOWITZ
Deputy City Attorney
By: ______________________
LISA BERKOWITZ
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO,
JOHN MARTIN, and BLAKE SUMMERS
PROPOSED ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
______________________
HON. JON S. TIGAR
United States District Judge