Rojas v. Loza et al

Filing 66

ORDER MODIFYING ORDER REGARDING PRETRIAL PREPARATIONS. The non-expert discovery deadline is extended to May 20, 2011 for the purpose of conducting depositions only. The deadline to designate experts is extended to June 3, 2011, and the deadline to di sclose rebuttal experts is extended to June 17, 2011. The expert discovery deadline is extended to July 6, 2011. The deadline to file dispositive motions is extended to July 29, 2011. Signed by Judge Maxine M. Chesney on March 31, 2011. (mmclc1, COURT STAFF) (Filed on 3/31/2011)

Rojas v. Loza et al

Doc. 66

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KARL J. KRAMER (CA SBN 136433) [e-mail] MATTHEW S. CHEN (CA SBN 253712) [e-mail] EMILY H. SHEFFIELD (CA SBN 269622) [e-mail] PETER H. DAY (CA SBN 275155) [e-mail] MORRISON & FOERSTER LLP 755 Page Mill Road Palo Alto, California 94304-1018 Telephone: [phone] Facsimile: 650.494.0792 Attorneys for Plaintiff JAHIR ALBERTO ROJAS KAMALA D. HARRIS Attorney General of California MICHAEL W. JORGENSON Supervising Deputy Attorney General D. ROBERT DUNCAN (CA SBN 161918) Deputy Attorney General EMILY L. BRINKMAN (CA SBN 219400) Deputy Attorney General 455 Golden Gate Avenue, Suite 11000 San Francisco, California 94102-7004 Telephone: [phone] Facsimile: 415.703.5843 E-Mail: [e-mail] Attorneys for Defendants R. LOZA, R. SINGH, and D. SANDOVAL UNITED STATES DISTRICT COURT

19 NORTHERN DISTRICT OF CALIFORNIA 20 SAN FRANCISCO DIVISION 21 22 JAHIR ALBERTO ROJAS, 23 Plaintiff, 24 v. 25 26 27 Defendants. 28
STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER RE PRETRIAL PREPARATIONS 3:07-CV-04662-MMC pa-1455192 Dockets.Justia.com

Case No.

3:07-CV-04662-MMC

R. LOZA, Correctional Officer; R. SINGH, Correctional Officer; D. SANDOVAL, Correctional Officer,

STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER REGARDING PRETRIAL PREPARATIONS The Honorable Maxine M. Chesney

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STIPULATION As a part of the meet and confer process, the parties agreed to file a stipulation extending the fact discovery cutoff for purposes of taking depositions, the expert discovery deadlines, and the deadlines to file dispositive motions. In order to allow completion of the discovery, the parties stipulate to and request the Court to issue an order modifying the Pretrial Preparation Order ("Scheduling Order"), filed on December 6, 2010 [Docket No. 57]. With the exception of the parties' proposed modifications, described below, the parties stipulate to and request that the Court order no changes to the remaining dates in the Scheduling Order. Non-Expert Discovery Cutoff. The Scheduling Order provides that fact discovery shall be completed by April 22, 2011. The parties stipulate to and request the Court to order an extension of this date to May 20, 2011 for the purpose of conducting depositions only. The parties stipulate that no further written discovery shall be propounded including requests for admissions, interrogatories, and production of documents under Federal Rules of Civil Procedure 33, 34, or 36 and subpoenas to produce documents under Rule of Civil Procedure 45. This stipulation, however, does not preclude or limit any parties' ability to request or compel further responses to discovery that has already been propounded provided any motion to compel fact discovery is filed on or before the existing deadline of April 29, 2011. See N.D. Cal. L.R. 37-3. Designation of Experts. The Scheduling Order provides for the deadlines as follows: Plaintiff/Defendant: No later than May 13, 2011. Plaintiff/Defendant: Rebuttal no later than May 27, 2011. The parties stipulate to and request the Court to order that these deadlines be extended as follows: Plaintiff/Defendant: No later than June 3, 2011. Plaintiff/Defendant: Rebuttal no later than June 17, 2011. Expert Discovery Cutoff. The Scheduling Order provides that all expert discovery shall be completed on or before June 15, 2011. The parties stipulate to and request the Court to order an extension of this date to July 6, 2011.

STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER RE PRETRIAL PREPARATIONS 3:07-CV-04662-MMC pa-1455192

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Dispositive Motions. The Scheduling Order further provides that the last day to file dispositive motions is July 8, 2011. The parties stipulate to and request the Court to order an extension of this date to July 29, 2011. All other pretrial dates shall remain the same.

Dated: March 28, 2011

KARL J. KRAMER MATTHEW S. CHEN EMILY H. SHEFFIELD PETER H. DAY MORRISON & FOERSTER LLP

By:

/s/ Matthew S. Chen MATTHEW S. CHEN Attorneys for Plaintiff JAHIR ALBERTO ROJAS

Dated: March 28, 2011

KAMALA D. HARRIS Attorney General of California MICHAEL W. JORGENSON Supervising Deputy Attorney General D. ROBERT DUNCAN Deputy Attorney General EMILY L. BRINKMAN Deputy Attorney General

By:

/s/ D. Robert Duncan D. ROBERT DUNCAN Attorneys for Defendants R. LOZA, R. SINGH, D. SANDOVAL

STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER RE PRETRIAL PREPARATIONS 3:07-CV-04662-MMC pa-1455192

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1 2 3 4 5 6 Dated: March 28, 2011 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

GENERAL ORDER 45 ATTESTATION I, Mathew S. Chen, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED ORDER MODIFYING ORDER REGADING PRETRIAL PREPARATIONS. In compliance with General Order 45, X.B., I hereby attest that D. ROBERT DUNCAN has concurred in this filing. By: /s/ Matthew S. Chen MATTHEW S. CHEN

STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER RE PRETRIAL PREPARATIONS 3:07-CV-04662-MMC pa-1455192

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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 31 Dated: March _____, 2011

ORDER PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

Honorable Maxine M. Chesney United States District Judge

STIPULATION AND [PROPOSED] ORDER MODIFYING ORDER RE PRETRIAL PREPARATIONS 3:07-CV-04662-MMC pa-1455192

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