Opinion
Case No. 2:10-CV-01807-LKK-DAD
10-31-2011
JERRY LUM, individually and as successor in interest to JEREMY LUM; DOROTHEA TIMMONS, individually and as successor in interest to JEREMY LUM Plaintiffs, v. COUNTY OF SAN JOAQUIN; CITY OF LATHROP; SERGEANT RAY WALTERS; SERGEANT STEVEN PEASE; DEPUTY DAVIS; OFFICER FELIPE MENDOZA and DOES 1 through 50, inclusive, Defendants.
WALKER, HAMILTON & KOENIG LLP Rana Ansari-Jaberi Attorneys for plaintiffs THE SUNTAG LAW FIRM P.C. Dana Suntag Attorneys for Defendants
Walter H. Walker, III, Esq. (SBN 63117)
Peter J. Koenig, Esq. (SBN 132437)
Rana Ansari-Jaberi, Esq. (SBN 262008)
WALKER, HAMILTON & KOENIG LLP
LAW OFFICES OF BORIS E. EFRON
Attorneys for Plaintiffs
STIPULATION AND ORDER EXTENDING EXPERT FRCP 26(a)(2)
REPORTS, DISCLOSURES AND DISCOVERY DEADLINES
The current deadline for the filing of Expert FRCP 26 reports and disclosures, in the above-referenced matter, is November 1, 2011. The parties have been working diligently on preparing this case for trial; they began propounding discovery in February 2011 and attempting to schedule depositions in July 2011. Thus far nine depositions have been completed and over 1,000 pages of discovery documents exchanged.
WHEREAS due to scheduling conflicts between witnesses, the parties and their counsel, certain deposition testimony and documents important for an expert to consider did not come to light until recently; and
WHEREAS the parties are working on resolving several discovery disputes that may affect both the necessity for certain expert disclosures and reports, and the substantive content of other experts' reports, and;
WHEREAS the parties wish to provide more meaningful and comprehensive reports pursuant to FRCP 26, in line with the goals of this Court and the purpose of these documents, and;
WHEREAS a one-month extension of the Expert FRCP 26 Reports and Disclosures and Discovery Deadlines would in no way affect this Court's Scheduling Order with respect to the law & motion deadline, the pretrial conference or the trial date,
IT IS HEREBY STIPULATED by and between the parties:
That the FRCP 26 expert disclosure and reports deadline, currently set for November 1, 2011, shall be extended until November 30, 2011;
That the discovery motion hearing deadline, currently set for November 30, 2011, shall be extended until December 31, 2011; and
That the discovery cut-off, currently set for December 31, 2011 shall be extended until January 31, 2012.
The parties request that the law & motion deadline, the pretrial conference and trial date remain as currently scheduled: February 29, 2012, May 29, 2012 and August 28, 2012, respectively.
WALKER, HAMILTON & KOENIG LLP
By: Rana Ansari-Jaberi
Attorneys for plaintiffs
THE SUNTAG LAW FIRM P.C.
By: Dana Suntag
Attorneys for Defendants
IT IS HEREBY ORDERED that the Scheduling Order be modified as follows:
+------------------------------------------------------------------------+ ¦Current ¦New ¦ +------------------------------------------------------+-----------------¦ ¦Expert Disclosure/Report Deadline: November 1, 2011 ¦November 30, 2011¦ +------------------------------------------------------+-----------------¦ ¦Discovery Motion Hearing Deadline: November 30, 2011¦December 31, 2011¦ +------------------------------------------------------+-----------------¦ ¦Discovery Cut-Off: December 31, 2011 ¦January 31, 2012 ¦ +------------------------------------------------------------------------+
LAWRENCE K. KARLTON
SENIOR JUDGE
UNITED STATES DISTRICT COURT
CERTIFICATE OF SERVICE
Willis, et al. v. City of Fresno, et al.
Case No. 1:09 CV 01766 LJO DLB
My business address is 50 Francisco Street, Suite 460, San Francisco, California 94133. I am employed in the County of San Francisco, where this mailing occurs. I am over the age of 18 years and not a party to the within cause.
I declare that on the date hereof, I served a copy of the following documents using the CM/ECF system which will send notifications of such filing to the parties denoted on the Electronic Mail Notice List, and I placed a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, addressed to the non-CM/ECF participants indicated on the Manual Notice List, for collection and mailing by the U.S. Postal Service in accordance with Walker, Hamilton & Koenig's ordinary business practices.
STIPULATION AND PROPOSED ORDER EXTENDING EXPERT FRCP 26(a)(2)
REPORTS, DISCLOSURES AND DISCOVERY DEADLINES
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct, and that this declaration was executed on October 31, 2011, at San Francisco, California.
RANA ANSARI-JABERI