Opinion
Case No.: CV 12-01922 MEJ
03-25-2013
GREGORY L. SULLIVAN and KOJI FUJITA, Plaintiffs, v. CITY OF SAN RAFAEL, a government entity; SAN RAFAEL POLICE DEPARTMENT, a government entity; RYAN DEMARTA, individually, and in his capacity as police officer for the CITY OF SAN RAFAEL; RYAN COGBILL, individually, and in his capacity as police officer for the CITY OF SAN RAFAEL; and DOES 1 to 100, Defendants.
Thomas F. Bertrand, SBN 056560 Richard W. Osman, SBN 167993 BERTRAND, FOX & ELLIOT Attorneys for Defendants CITY OF SAN RAFAEL, RYAN DEMARTA and RYAN COGBILL James D. Rush, SBN 240284 LAW OFFICES OF JAMES D. RUSH, APC Attorney for Plaintiffs GREGORY L. SULLIVAN and KOJI FUJITA Brian K. Gearinger, SBN 146125 GEARINGER LAW GROUP Attorneys for Plaintiffs GREGORY L. SULLIVAN and KOJI FUJITA
Thomas F. Bertrand, SBN 056560
Richard W. Osman, SBN 167993
BERTRAND, FOX & ELLIOT
Attorneys for Defendants
CITY OF SAN RAFAEL,
RYAN DEMARTA and RYAN COGBILL
James D. Rush, SBN 240284
LAW OFFICES OF JAMES D. RUSH, APC
Attorney for Plaintiffs
GREGORY L. SULLIVAN and
KOJI FUJITA
Brian K. Gearinger, SBN 146125
GEARINGER LAW GROUP
Attorneys for Plaintiffs
GREGORY L. SULLIVAN and
KOJI FUJITA
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DATE FOR DISCLOSURE OF
EXPERTS AND DISCLOSURE OF
REBUTTAL EXPERTS
The parties, by and through their respective counsel, hereby stipulate and request that the presently-scheduled March 29, 2013 Expert Disclosure date be continued to April 23, 2013, and the April 8, 2013 Rebuttal Expert Disclosure date be continued to May 3, 2013 based on the following:
The last day to complete fact discovery in this matter is April 23, 2013.
Multiple depositions are scheduled during the next several weeks and the parties intend to have their experts review and potentially include information from these depositions in their FRCP Rule 26 reports. Moving the expert disclosure dates will accommodate this.
Continuing the Expert Disclosure date and the Rebuttal Expert date will not affect any other dates in this case.
SO STIPULATED.
BERTRAND, FOX AND ELLIOT
By: _____________________
Richard W. Osman
Attorneys for Defendants
LAW OFFICE OF JAMES D. RUSH
By:_____________________
James D. Rush
Attorneys for Plaintiffs
GEARINGER LAW GROUP
By: _____________________
Brian K. Gearinger
Attorneys for Plaintiffs
[PROPOSED] ORDER
Having reviewed the stipulation of counsel herein, IT IS HEREBY ORDERED that the Expert Disclosure date is continued from March 29, 2013 to April 23, 2013 and the Rebuttal Expert date is continued from April 8, 2013 to May 3, 2013.
IT IS SO ORDERED.
_____________________
HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE