Paz v. City and County of San Francisco et al

Filing 29

ORDER GRANTING PARTIES' STIPULATION CONTINUING TRIAL DATE. The parties' stipulation to continue the trial date in this action from January 31, 2011 to May 9, 2011 is granted. The scheduled pretrial conference is continued from January 18, 2011 to April 26, 2011. Signed by Judge Maxine M. Chesney on August 12, 2010. (mmclc2, COURT STAFF) (Filed on 8/12/2010)

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DENNIS J. HERRERA, State Bar #139669 City Attorney BLAKE P. LOEBS, State Bar #145790 ANDREW M. GSCHWIND, State Bar #231700 Deputy City Attorneys 1390 Market Street, 6th Floor San Francisco, California 94102-5408 Telephone: [phone] Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO and RONALD M. CHOY Charles Geerheart, Esq. PAOLI & GEERHART, LLP 785 Market Street, Suite 1150 San Francisco, CA 94103 Telephone: [phone] Attorneys for Plaintiff LEOPOLDO PAZ-HERRERA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA LEOPOLDO PAZ-HERRERA, Plaintiff, vs. CITY AND COUNTY OF SAN FRANCISCO; RONALD M. CHOY and DOES 1-30, Defendant. Case No. C09-4795 MMC STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL DATE

Plaintiff Leopoldo Paz-Herrera ("Plaintiff") and Defendants City & County of San Francisco and Ronald M. Choy ("Defendants"), by and through their respective counsel, hereby stipulate and agree, subject to the Court's approval, to continue the trial date in this action from January 31, 2011 to May 9, 2011 or as soon thereafter as the Court can accommodate. The basis for submitting this stipulation and proposed order is as follows. Deputy City Attorney Blake Loebs, the lead and senior attorney representing Defendants in this action, will be off
STIP & [PROPOSED] ORDER CONTINUING TRIAL DATE Case No. C09-4795 MMC

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work on family leave in January of 2011 due to the anticipated arrival of his first child. Due to Mr. Loebs' family leave, defense counsel had requested that plaintiff's counsel agree to a thirty to fortyfive day continuance of the trial in this action. However, plaintiff's counsel, Charles Geerhart, Esq. of Paoli & Geerhart, has several jury trials and other important events scheduled in and around or between late February, 2011 and early May, 2011. Accordingly, counsel for the parties request that the Court continue the trial in this action to the earliest available trial date convenient for all counsel, or to May 9, 2011, and/or the earliest available date after this time that is convenient to the Court. The parties request that the Pretrial Conference Date be moved from January 18, 2011 to April 26, 2011 at 3:00 p.m. and/or to another date and time convenient to the Court. All other dates -- expert disclosures and discovery, dispositive motion deadline, and a further status conference on Nov. 5, 2010 -- shall remain unchanged.

Dated: August 10, 2010 DENNIS J. HERRERA City Attorney JOANNE HOEPER Chief Trial Deputy BLAKE P. LOEBS ANDREW M. GSCHWIND Deputy City Attorneys By: /s./ ANDREW M. GSCHWIND Attorneys for Defendants

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Dated: August 10, 2010 PAOLI & GEERHART, LLP

By:

/s./1 CHARLES GEERHART Attorneys for Plaintiff

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED: The trial date in this action is hereby continued to [May 9, 2011] [or, alternatively] [______________, 2011]. The Pretrial Conference in this action is hereby continued to [April 26, 2011] [or, alternatively] [_______________, 2011 at 3:00 p.m.] Lead trial counsel shall meet and confer no later than March 20, 2011 [or, alternatively][ _______________, 2011.] All other currently-scheduled dates in this action shall remain the same.

Date: August 12, 2010

By: THE HON. MAXINE M. CHESNEY United States District Court Judge

Per General Order 45, section X.B., defense counsel hereby attests that he has obtained the concurrence, consent and authorization of Mr. Geerhart to file this document on his behalf.
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