Redd, et al v. Daley, et al

Filing 237

STIPULATION AND ORDER re 236 STIPULATION WITH PROPOSED ORDER To Continue Discovery Cutoff Dates filed by Paul A. Redd, Jr. Discovery due by 2/2/2015.. Signed by Judge Edward M. Chen on 11/26/14. (bpf, COURT STAFF) (Filed on 11/26/2014)

1
2
3
4
5
6

RISHI N. SHARMA (Cal. State Bar No. 239034)
PETER A. COOPER (Cal. State Bar No. 275300)
PAUL HASTINGS LLP
55 Second Street, 24th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
Paul A. Redd, Jr.

7
8
9
10
11
12
13
14
15

KAMALA D. HARRIS
Attorney General of California
DANIELLE F. O'BANNON
Supervising Deputy Attorney General
TRACE O. MAIORINO
Deputy Attorney General
SHARON A. GARSKE
Deputy Attorney General
State Bar No. 215167
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant
Michael D. Daley

16
17

UNITED STATES DISTRICT COURT

18

NORTHERN DISTRICT OF CALIFORNIA

19
20

PAUL A. REDD, JR.,

21
Plaintiff,
22
23
24

No. C 98-20429 EMC
JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DISCOVERY
CUT OFF DATES

vs.
MICHAEL D. DALEY,

25
Defendant.
26
27
28
LEGAL_US_W # 80356067.2

JOINT STIPULATION & ORDER TO CONTINUE
DISCOVERY CUT OFF DATES
U.S.D.C., N.D. Cal., No. C 98-20429 EMC

1

JOINT STIPULATION

2

Pursuant to Local Rule 6-2, Plaintiff Paul A. Redd, Jr. and Defendant Michael D. Daley, by and

3

through their respective counsel of record, hereby jointly stipulate and respectfully request the Court

4

enter an order as follows:

5
6

1.

On October 20, 2014, the Court issued its Case Management and Pretrial Order for Jury

Trial (ECF 234). In the Order, the Court set the following discovery deadlines:

7



Non-expert discovery cut off:

December 4, 2014

8



Opening expert reports:

December 4, 2014

9



Rebuttal expert reports:

December 26, 2014

10



Expert discovery cut off:

January 15, 2015

11
12
13
14

2.

Since the Court’s order, the parties have engaged in discussions regarding settlement of

Plaintiff’s claims and scheduling discovery so as not to prejudice their direct settlement discussions.
3.

Accordingly, in order for the parties to explore fully the possibility of settlement of this

action, the parties’ respectfully request that the Court continue the discovery deadlines as follows:

15



Non-expert discovery cut off:

February 2, 2015

16



Opening expert reports:

February 2, 2015

17



Rebuttal expert reports:

February 23, 2015

18



Expert discovery cut off:

March 9, 2015

19
20

4.

The filing of this stipulation does not affect the other case management deadline set by

the Court in the October 20, 2014, Order, including the trial and pre-trial dates.

22

RISHI N. SHARMA
PETER A. COOPER
PAUL HASTINGS LLP

23

By: s/

21

Dated: November 24, 2014

24

26

TRACE O. MAIORINO
SHARON A. GARSKE
CALIFORNIA ATTORNEY GENERAL’S OFFICE

27

By: s/

25

Dated: November 24, 2014

Peter A. Cooper
Peter A. Cooper
Attorneys for Plaintiff Paul A. Redd, Jr.

28
LEGAL_US_W # 80356067.2

Sharon A. Garske
Sharon A. Garske
Attorneys for Defendant Michael D. Daley
JOINT STIPULATION & ORDER TO CONTINUE
DISCOVERY CUT OFF DATES
U.S.D.C., N.D. Cal., No. C 98-20429 EMC

1

ORDER

2

On the stipulation of the parties, and good cause appearing therefor,

3

IT IS ORDERED that the discovery deadlines set in the October 20, 2014, Case Management

4

and Pretrial Order for Jury Trial (ECF 234) be and hereby are continued as follows:

5



Non-expert discovery cut off:

February 2, 2015

6



Opening expert reports:

February 2, 2015

7



Rebuttal expert reports:

February 23, 2015

8



Expert discovery cut off:

March 9, 2015

14

NO

RT

15

ER

17

A

H

16

United States District Judge
n
M. Che
Edward
Judge

R NIA

13

D
RDERE
S SO OM. Chen
IT I Edward

FO

12

S DISTRICT
TE
C
TA

LI

26
Dated: November __, 2014

RT
U
O

11

this order.

S

10

IT IS FURTHER ORDERED that no other case management deadlines are otherwise affected by

UNIT
ED

9

N

F
D IS T IC T O
R

C

18
19
20
21
22
23
24
25
26
27
28
LEGAL_US_W # 80356067.2

ORDER TO CONTINUE
DISCOVERY CUT OFF DATES
U.S.D.C., N.D. Cal., No. C 98-20429 EMC