Davis v. Prison Health Services, Inc. et al

Filing 100

ORDER ADJUSTING DISCOVERY DEADLINES (tf, COURT STAFF) (Filed on 8/12/2011)

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PAMELA Y. PRICE (STATE BAR NO. 107713)
JESHAWNA R. HARRELL (STATE BAR NO. 257773)
PRICE AND ASSOCIATES
A Professional Law Corporation
1611 Telegraph Avenue, Suite 1453
Oakland, CA 94612
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
FANIA E. DAVIS, ESQ. (STATE BAR NO. 87268)
4100 Redwood Road, #371
Oakland, CA 94109
Telephone: [phone]

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DARRYL PARKER, ESQ. (STATE BAR NO. 95914)
PREMIER LAW GROUP
3131 Elliott Avenue, Suite 710
Seattle, WA 98121
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
FREDDIE M. DAVIS
[Refer to signature page for the complete list of parties represented]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FREDDIE M. DAVIS,
Plaintiff,

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v.
PRISON HEALTH SERVICES; et al.,

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Defendants.

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Case No. C09-02629 SI
STIPULATION AND [PROPOSED]
ORDER TO MODIFY CASE
MANAGEMENT ORDER
[FRCP 16(b)(4)]

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Pursuant to Federal Rule of Civil Procedure 16(b)(4), Plaintiff Freddie M. Davis and
Defendants County of Alameda, James E. Ayala, and Darryl Griffith hereby stipulate as follows:
WHEREAS, the Court’s current Case Management Order sets the following schedule for
expert discovery: Expert Disclosures, August 5, 2011, Rebuttal Disclosures August 19, 2011, and
Expert Discovery Cut-off September 9, 2011; and
{00074331.DOC/}1

STIPULATION TO MODIFY CASE MANAGEMENT ORDER

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WHEREAS, Plaintiff Freddie Davis’ mother, a resident of Birmingham, Alabama, is
gravely ill in hospice; and

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WHEREAS, the forensic psychologist retained by Plaintiff has had insufficient time with

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Ms. Davis to complete the requisite extensive psychological testing and interviewing because Ms.

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Davis has had to travel to Alabama to be at her mother’s bedside during recent weeks; and

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WHEREAS, based upon good cause shown, the parties request that the Court extend
expert disclosure and discovery deadlines;

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WHEREAS, the parties have previously requested three modifications of the Case
Management Order by stipulation;

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NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, based

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on the foregoing circumstances, to request that the Court establish the following modified

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deadlines:

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Expert Disclosures

August 15, 2011

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Rebuttal Expert Disclosures

August 29, 2011

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Expert Discovery Cut-Off

September 19, 2011

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Dated: _____________________

/s/
FANIA E. DAVIS
Attorney for Plaintiff
FREDDIE M. DAVIS

Dated: _____________________

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/s/
LYNNE G. STOCKER
ANDRADA & ASSOCIATES
Attorneys for Defendants
COUNTY OF ALAMEDA, JAMES E. AYALA,
And DARRYL GRIFFITH

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IT IS SO ORDERED.
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Dated:

8/11/11
SUSAN ILLSTON
United States District Judge
{00074331.DOC/}2

STIPULATION TO MODIFY CASE MANAGEMENT ORDER