Alemozaffar v. City and County of San Francisco et al

Filing 65

ORDER Granting 64 Stipulation re Discovery. Signed by Judge Jeffrey S. White on February 4, 2009. (jswlc1, COURT STAFF) (Filed on 2/4/2009)

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Case 3:07-cv-04494-JSW Document 64 Filed 02/03/2009 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DENNIS J. HERRERA, State Bar #139669 City Attorney JOANNE HOEPER, State Bar #114961 Chief Trial Deputy SCOTT D. WIENER, State Bar #189266 DANIEL A. ZAHEER, State Bar #237118 Deputy City Attorney 1390 Market Street, 7th Floor San Francisco, California 94102-5408 Telephone: (415) 554-4283 Facsimile: (415) 554-3837 Attorneys for Defendants UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA MEHRDAD ALEMOZAFFAR, Plaintiff, vs. CITY AND COUNTY OF SAN FRANCISCO, a municipal corporation; JESSE SERNA, individually and in his official capacity as a police officer for the CITY AND COUNTY OF SAN FRANCISCO; GARY MORIYAMA, individually and in his official capacity as a police officer for the CITY AND COUNTY OF SAN FRANCISCO; J MCGRATH, individually and in his official capacity as a police officer for the CITY AND COUNTY OF SAN FRANCISCO; J. REYMUNDO, individually and in his official capacity as a deputy sheriff officer for the CITY AND COUNTY OF SAN FRANCISCO; G. COVIELLO, , individually and in his official capacity as a deputy sheriff officer for the CITY AND COUNTY OF SAN FRANCISCO. Defendants. Case No. C07-4494 JSW STIPULATION AND [PROPOSED] ORDER RE DISCOVERY ON LOSTEARNINGS CLAIM BY PLAINTIFF Alemozaffar v. CCSF, et al. USDC No. C07-4494 JSW 1 n:\lit\li2007\080046\00536267.doc Case 3:07-cv-04494-JSW Document 64 Filed 02/03/2009 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WHEREAS the parties disclosed experts on January 30, 2009; WHEREAS plaintiff disclosed several experts who opined that Plaintiff has reduced ability to earn income in the future as a surgeon as a result of injuries sustained during the subject incident; WHEREAS based on such expert opinions, Plaintiff is making a wage-loss claim that may be as large as $8,000,000; WHEREAS the parties have a dispute about whether Plaintiff adequately disclosed this wage-loss claim during discovery, with Plaintiff contending that he did and that the claim is therefore proper, and Defendants contending that he did not and that the claim is therefore excludable on motion to strike or motion in limine; AND WHEREAS the parties have met and conferred and determined that discovery into the wage-loss claim is appropriate at this point in time; THE PARTIES HEREBY AGREE AND STIPULATE, subject to approval of the Court, that Defendants may take discovery into Plaintiff's wage-loss claim by subpoenaing Plaintiff's employment records and taking appropriate depositions. Dated: February 3, 2009 DENNIS J. HERRERA City Attorney JOANNE HOEPER Chief Trial Deputy SCOTT D. WIENER DANIEL A. ZAHEER Deputy City Attorney - /s/ - Scott D. Wiener By: SCOTT D. WIENER Attorneys for Defendants Alemozaffar v. CCSF, et al. USDC No. C07-4494 JSW 2 n:\lit\li2007\080046\00536267.doc Case 3:07-cv-04494-JSW Document 64 Filed 02/03/2009 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: February 3, 2009 LAW OFFICES OF SANFORD M. CIPINKO - /s/ - Jeremy Cloyd By: JEREMY CLOYD Attorneys for Plaintiff MEHRDAD ALEMOZAFFAR *Pursuant to GO 45, the electronic signatory has obtained approval from this signatory. SO ORDERED. February 4, 2009 Dated: __________________ _______________________________________ HON. JEFFREY S. WHITE UNITED STATES DISTRICT JUDGE Alemozaffar v. CCSF, et al. USDC No. C07-4494 JSW 3 n:\lit\li2007\080046\00536267.doc

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