Reed et al v. City of Modesto et al

Filing 122

STIPULATION and ORDER to Continue Briefing and Hearing Dates of Motions in Limine, signed by District Judge Anthony W. Ishii on 3/9/2015. (It is hereby ORDERED that the briefing and hearing dates on any additional motions in limine are continued as follows: Motions in limine to be filed by 4/8/2015, Responses due by 4/13/2015, Replies due by 4/15/2015, and Trial Confirmation/ Motions in Limine Hearing previously set for 4/13/2015, has been CONTINUED to 4/20/2015, at 01:30 PM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii.)(Gaumnitz, R)

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Susan E. Coleman (SBN 171832)
E-mail: [e-mail]
Nathan A. Oyster (SBN 225307)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Tel: [phone]; Fax: [phone]
Attorneys for Defendants CITY OF
MODESTO and OFFICER RON ZIYA

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BRIAN REED, B.R., a minor, by her
guardian ad litem, Roxanne Sayer,
Plaintiffs,
v.
CITY OF MODESTO, a municipal
corporation, Chief of Police
HARDEN, in his individual capacity;
Police Officer RON ZIYA, Police
Officer CAELI KOEHLER, in their
individual and official capacities,

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Defendants.

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Case No. 1:11-cv-01083-AWI-GSA
STIPULATION AND ORDER TO
CONTINUE BRIEFING AND
HEARING DATES OF MOTIONS IN
LIMINE
CURRENT DATES:
L/D to file MILs: March 11, 2015
L/D to file Opps: March 25, 2015
L/D to file Replies: April 2, 2015
Hearing Date: April 13, 2015, 1:30 p.m.
PROPOSED DATES:
L/D to file MILs: April 8, 2015
L/D to file Opps: April 13, 2015
L/D to file Replies: April 15, 2015
Hearing Date: April 20, 2015, 1:30 p.m.

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Hon. Anthony W. Ishii

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Trial: April 28, 2015

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Plaintiffs BRIAN REED and B.R., through her guardian ad litem, Roxanne

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Sayers, (hereinafter “Plaintiffs”) and Defendants CITY OF MODESTO and

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OFFICER RON ZIYA (hereinafter “Defendants”), through their counsel of record,

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hereby stipulate and agree as follows:

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4847-4707-5106 v1

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STIPULATION AND [PROPOSED] ORDER TO
CONTINUE BRIEFING AND HEARING DATES
OF MOTIONS IN LIMINE

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1.

On February 10, 2015, the Court issued an Order [Docket No. 120]

setting the following dates:

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Trial: April 28, 2015, 8:30 a.m., in Courtroom 2

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Any additional motions in limine: March 11, 2015

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Any opposition: March 25, 2015

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Any reply: April 2, 2015

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Hearing on the motions in limine: April 13, 2015, 1:30 p.m.

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Trial brief: April 9, 2015

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Any response to a trial brief: April 17, 1015

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Proposed jury instructions and verdict forms: April 16, 2015

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Final witness list: April 23, 2015

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List of all discovery documents for use at trial: April 23, 2015

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Proposed voir dire questions: April 23, 2015

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Joint agreed summary of the case: April 23, 2015

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2.

Pursuant to the parties’ previous agreement, the parties have scheduled

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the depositions of eight expert witnesses in this case. The series of eight expert

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depositions will commence on March 19, 2015 and conclude on April 6, 2015. The

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parties wish to continue the briefing deadlines and the hearing dates for any

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additional motions in limine to allow these eight expert depositions to be completed

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prior to the motion in limine filing deadline.

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3.

Accordingly, the parties request an Order continuing the filing

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deadline for any additional motions in limine from March 11, 2015 to April 8,

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2015, continuing the deadline to file oppositions from March 25, 2015 to April 13,

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2015, continuing the deadline to file reply briefs from April 2, 2015 to April 15,

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2015, and continuing the hearing date on any motions in limine and the trial

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readiness conference from April 13, 2015 to April 20, 2015 at 1:30 p.m.

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IT IS SO STIPULATED.

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4847-4707-5106 v1

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Dated: March 6, 2015

Law Office of Steven Yourke

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By: /s/ Steven R. Yourke
[As approved on March 6, 2015]
Steven R. Yourke

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Attorneys for Plaintiffs
BRIAN REED, B.R., a minor, by her
guardian ad litem, Roxanne Sayers

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Dated: March 6, 2015

Burke, Williams & Sorensen, LLP

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By: /s/ Nathan A. Oyster
Susan E. Coleman
Nathan A. Oyster

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Attorneys for Defendants
CITY OF MODESTO, CHIEF OF
POLICE MICHAESL HARDEN, AND
OFFICERS RON ZIYA AND CAELLI
KOEHLER, MUNICIPAL EMPLOYEES

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ORDER
Having reviewed the parties’ Stipulation and finding good cause therefor, it
is hereby ORDERED that the briefing and hearing dates on any additional motions
in limine are continued as follows:
L/D to file motions in limine: April 8, 2015
L/D to file oppositions: April 13, 2015
L/D to file replies: April 15, 2015
Hearing on Motions in Limine and Trial Readiness Conference: April 20,
2015, 1:30 p.m.
IT IS SO ORDERED.
Dated: March 9, 2015
SENIOR DISTRICT JUDGE

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4847-4707-5106 v1

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