Opinion
Case No.: CV 12-01922 MEJ
05-09-2013
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 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 Gearinger, SBN 146125
GEARINGER LAW GROUP
Attorneys for Plaintiffs
GREGORY L. SULLIVAN and
KOJI FUJITA
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DATES FOR EXPERT
DISCLOSURES AND DISCLOSURES OF
REBUTTAL EXPERTS
STIPULATION
1. The parties, by and through their respective counsel, hereby stipulate and request that the presently-scheduled May 7, 2013 Expert Disclosure date be continued to May 17, 2013, and the May 17, 2013 Rebuttal Expert Disclosure date be continued to May 31, 2013.
2. Brian Gearinger, co-counsel for Plaintiffs, is responsible for retaining Plaintiffs' police practices expert and providing all relevant materials to the expert necessary for the expert's preparation of his Federal Rule of Civil Procedure 26(a)(2)(B) written report. Mr. Gearinger will be attending a funeral out-of-state such that he will not be able to oversee the timely completion of the report of Plaintiff's police practices. Mr. Gearinger explained his situation to Richard Osman, counsel for Defendants. Mr. Osman graciously agreed to stipulate to Mr. Gearinger's request to extend the deadlines relating to Expert Disclosures and Rebuttal Expert Disclosures.
3. Moving 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 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 May 7, 2013 to May 17, 2013 and the Rebuttal Expert date is continued from May 17, 2013 to May 31, 2013.
IT IS SO ORDERED.
________________________
HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE