Davis v. Prison Health Services, Inc. et al

Filing 89

ORDER extending discovery deadlines (tf, COURT STAFF) (Filed on 7/14/2011)

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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
AMENDED 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, Defendants’ motion for summary judgment was originally set for hearing on
June 24, 2011;

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STIPULATION TO MODIFY CASE MANAGEMENT ORDER

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WHEREAS, the Court’s Case Management Order sets the following schedule for expert

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discovery: Expert Disclosures, July 15, 2011, Rebuttal Disclosures July 20, 2011, and Expert

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Discovery Cut-off August 19, 2011;

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WHEREAS, for good cause shown, the Court previously rescheduled the dispositive
motion briefing and hearing schedule to accommodate a new hearing date of July 15, 2011;

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WHEREAS, based upon the preference of the parties to obtain the Court’s ruling on the

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dispositive motion prior to incurring the substantial expense of retaining and/or disclosing

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experts, the previous Scheduling Order allowed three weeks from the date of the dispositive

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motion hearing to make expert disclosures;

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WHEREAS the parties continue to hold the view that it is more prudent and economical to

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await the decision of the Court on the summary judgment motion before incurring the

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considerable expense of retaining and/or disclosing experts; and

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WHEREAS, the parties request that the Court similarly allow three weeks from the new

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date of the dispositive motion hearing to begin the process of making expert disclosures, rebuttal

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disclosures and expert discovery; and

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WHEREAS, the parties have previously requested two 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 5, 2011

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Rebuttal Expert Disclosures

August 19, 2011

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Expert Discovery Cut-Off

September 9, 2011

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Dated: July 11, 2011

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

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STIPULATION TO MODIFY CASE MANAGEMENT ORDER

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Dated: July 11, 2011

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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:

7/13/11
SUSAN ILLSTON
United States District Judge

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STIPULATION TO MODIFY CASE MANAGEMENT ORDER