Ambat et al v. City & County of San Francisco et al

Filing 170

ORDER PERMITTING EXTENSION ON DATES FOR COMMENCING DEPOSITIONS OF EXPERT WITNESSEs (tf, COURT STAFF) (Filed on 12/21/2009)

Case3:07-cv-03622-SI Document169 Lawrence D. Murray (SBN 77536) MURRAY & ASSOCIATES 1781 Union Street San Francisco, CA 94123 Tel:[phone] Fax: [phone] Attorneys For Plaintiffs DENNIS J. HERRERA (SBN 139669) City Attorney ELIZABETH S. SALVESON (SBN 83788) Chief Labor Attorney MARGARET BAUMGARTNER (SBN 151762) RAFAL OFIERSKI (SBN 194798) Deputy City Attorneys Fax Plaza 1390 Market Street, Fifth Floor San Francisco, CA 94102 Tel: [phone] Fax: [phone] Attorneys For Defendant CITY AND COUNTY OF SAN FRANCISCO

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UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA MERCY AMBAT et al. Plaintiffs, vs. CITY AND COUNTY OF SAN FRANCISCO, STIPULATION FOR ORDER AND ORDER PERMITTING EXTENSION ON DATES FOR COMMENCING DEPOSITIONS OF EXPERT WITNESSES No. Case No. C-07-3622 SI (including No: C-08-2406 SI & C-09-2652 SI)

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Defendant.

Plaintiffs and Defendant CITY AND COUNTY OF SAN FRANCISCO, by and through their respective attorneys of record, hereby stipulate and request the Court to further modify the Pre-Trial Scheduling Order by extending: (a) All expert rebuttal reports, if any, shall be exchanged no later than December 18, 2010. (b) All depositions of rebuttal experts, if any, shall be completed by January 8, 2010.
Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI Page 1 STIPULATION FOR ORDER AND ORDER PERMITTING EXTENSION ON DATES FOR COMMENCING DEPOSITIONS OF EXPERT WITNESSES

Case3:07-cv-03622-SI Document169

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(c) All depositions of Plaintiffs' Experts regarding damages shall be completed by February 26, 2010. (d) The deposition of Ric Fatone Zayas shall be completed the week of January 11, 2010. Furthermore, the motions for summary judgment are scheduled to be filed no later than January 8, 2010, the opposition is due by January 22, 2010, the reply is due January 29,2010, and hearing on the summary judgment no later than February 12, 2010. Jury trial in this case is currently scheduled for March 29, 2010. None of these dates need be changed. Good cause exists to alter the completion dates for particular Expert Witnesses because the parties have been actively scheduling, calendaring, and completing depositions for expert witnesses' whose testimony is necessary for the filing of the parties' upcoming dispositive motions. Granting an extension for the completion of damage experts' depositions would save the unnecessary waste of the parties' time and resources. For this reason, the parties respectfully request the Court modify the Pre-Trial Scheduling Order so that expert disclosure conforms to the foregoing new dates.

Date: December 15, 2009

MURRAY & ASSOCIATES
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SAN FRANCISCO CITY ATTORNEY OFFICE

/s/Lawrence D. Murray Lawrence D. Murray Attorney for Plaintiffs

/s/Margaret W. Baumgartner_ Margaret W. Baumgartner Attorney for Defendant City and County of San Francisco.

Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI Page 2 STIPULATION FOR ORDER AND ORDER PERMITTING EXTENSION ON DATES FOR COMMENCING DEPOSITIONS OF EXPERT WITNESSES

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ORDER ON STIPULATION FOR ORDER HAVING READ AND CONSIDERED THE FOREGOING, and good cause appearing: The foregoing is the order of the court.

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Date:

________________________________________ SUSAN ILLSTON UNITED STATES DISTRICT COURT JUDGE

Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI Page 3 STIPULATION FOR ORDER AND ORDER PERMITTING EXTENSION ON DATES FOR COMMENCING DEPOSITIONS OF EXPERT WITNESSES