Foster v. City of Oakland et al

Filing 30

ORDER AND STIPULATION RE: Expert Witness Disclosure re 29 . Signed by Judge Elizabeth D. Laporte on 3/23/09. (lmh, COURT STAFF) (Filed on 3/23/2009)

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Eugene B. Elliot, State Bar No. 111475 Christine Lee, State Bar No. 231617 Joshua K. Clendenin, State Bar No. 245564 BERTRAND, FOX & ELLIOT The Waterfront Building 2749 Hyde Street San Francisco, California 94109 Telephone: [phone] Facsimile: [phone] Vicki A. Laden, State Bar Number 130147 Supervising Deputy City Attorney Oakland City Attorney's Office One Frank Ogawa Plaza, 6th Floor Oakland, CA 94612 Tel. [phone] Fax [phone] Attorneys for Defendant CITY OF OAKLAND

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

MICHAEL FOSTER. vs. Plaintiff,

CITY OF OAKLAND, AUDREE JONESTAYLOR, and DOES 1-50, inclusive, Defendants

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Case No.: CV-08-1944 EDL [PROPOSED] ORDER AND STIPULATION RE: EXPERT WITNESS DISCLOSURE

TO ALL PARTIES AND THEIR ATTORNEY OF RECORD: The parties, acting by and through their respective legal counsel, hereby stipulate to the following changes to paragraph 2(b) and 2(c) of the Case Management and Pretrial Order For Jury Trial issued by the Honorable Elizabeth D. Laporte on July 25, 2008 (the Order). Paragraph 2(b) of the Order dealing with discovery is revised as follows: Initial expert witness disclosure shall be made no later than April 10, 2009. Rebuttal expert disclosures shall be made no later than May 1, 2009. All treating physicians who will provide
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STIPULATION AND [PROPOSED] ORDER RE EXPERT WITNESS DISCLOSURE

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opinion testimony beyond that which can be provided by a lay person must be disclosed as expert witnesses, but they need not prepare expert reports unless ordered to do so by the Court. Paragraph 2(c) of the Order dealing with discovery is revised as follows: All expert discovery shall be completed no later than May 22, 2009. There will be no further expert discovery after that date except by order of the Court for good cause shown. Motions to compel expert discovery must be filed within the time limits contained in Civil Local Rule 26-2. So Stipulated. Dated: March 20, 2009 Law Offices of Charles A. Bonner

By:

/s/ Cabral Bonner Catherine Lagarde Attorneys for Plaintiff MICHAEL FOSTER

Dated: March 20, 2009

BERTRAND, FOX, & ELLIOT

By:

/s/ Eugene B. Elliot Christine Lee Attorneys for Defendant CITY OF OAKLAND

Good cause appearing, the stipulation is so ordered.

Dated: March 23, 2009

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STIPULATION AND [PROPOSED] ORDER RE EXPERT WITNESS DISCLOSURE

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______________________________ The Honorable ElizabethRDLaporte D. ERED OO U.S. DistrictT IS SMagistrate Judge I Court

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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 Dated: March 20, 2009

ATTORNEY ATTESTATION I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this E-filed document.

/s/ Christine Lee

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STIPULATION AND [PROPOSED] ORDER RE EXPERT WITNESS DISCLOSURE