Halali v. United States of America et al

Filing 43

STIPULATION AND ORDER RE 42 EXPERT DEPOSITION DISCOVERY AND FURTHER CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 12/1/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 9/27/11. (cl, COURT STAFF) (Filed on 9/27/2011)

*E-Filed 9/27/11*

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MELINDA HAAG (CSBN 132612)
United States Attorney
JOANN M. SWANSON (CSBN 88143)
Chief, Civil Division
MICHAEL T. PYLE (CSBN 172954 )
JAMES A. SCHARF (CSBN 152171)
Assistant United States Attorneys
U.S. Attorney’s Office/Civil Division/San Jose Branch
150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Defendant United States of America
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ALI R. MOGHADDAMI (CSBN 174548)
Moghaddami & Sadigh
333 East Glenoaks Boulevard, Suite 202
Glendale, CA 91207-2099
TEL: [phone]
FAX: [phone]
E-mail: [e-mail]

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MICHAEL L. ORAN (CSBN 110970)
Law Office of Michael L. Oran
800 Wilshire Boulevard
Suite 500
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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BENHAM HALALI,
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)
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Plaintiff,
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v.
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UNITED STATES OF AMERICA ET AL., )
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Defendants.
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No. 09-4900 RS
STIPULATION AND [PROPOSED]
ORDER RE EXPERT DEPOSITION
DISCOVERY AND FURTHER CMC

JOINT CASE MANAGEMENT CONFERENCE STATEMENT
Halali v. USA, Case No. 09-4900 RS

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Whereas, the parties have completed all non-expert discovery, in compliance with the Court’s
April 21, 2011, Case Management Scheduling Order, Document 41, (“CMSO”).
Whereas, plaintiff served his expert disclosures on September 16, 2011, in compliance with
the CMSO.
Whereas, defendant will serve its expert disclosures on November 4, 2011, in compliance
with the CMSO.
Whereas, the CMSO provides that expert deposition discovery must be completed by
November 18, 2011.

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Whereas, a Further Case Management conference is set for November 17, 2011, at 10:00 a.m.

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Whereas, the parties have scheduled a full-day, private mediation with Charlie Hawkins on

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November 22, 2011.

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Whereas, in order to conserve resources, the parties desire to briefly postpone expert

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deposition discovery and the Further Case Management Conference until after the mediation.

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Whereas, the requested postponement will not affect any of the other dates imposed by the

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CMSO, including the February 2, 2012, Pretrial Conference and the February 13, 2012, Trial.

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Therefore, the parties jointly request the Court to extend expert deposition discovery to

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December 23, 2011. The parties further request that the Further Case Management Conference

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be continued to December 1, 2011, at 10:00 a.m., or to any date thereafter that may be more

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convenient to the Court.

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Dated: September 23, 2011

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Respectfully submitted,
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MELINDA HAAG
United States Attorney

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By:

________/S/_________
JAMES A. SCHARF
Assistant United States Attorney
Attorney for Defendant

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STIPULATION AND [PROPOSED] ORDER RE EXPERT DEPOSITION DISCOVERY AND FURTHER CMC
C09-4900 RS

LAW OFFICE OF MICHAEL L. ORAN

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By:

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_______/S/________
MICHAEL L. ORAN
Attorney for Plaintiff

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Pursuant to the parties’ stipulation, and good cause appearing, it is hereby ordered:
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Expert deposition discovery is extended to December 23, 2011. The Further Case Management
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Conference is continued to December 1, 2011, at 10:00 a.m. [or] [____________________].
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Dated: September __, 2011

_____________________________
Hon. Richard Seeborg
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER RE EXPERT DEPOSITION DISCOVERY AND FURTHER CMC
C09-4900 RS