Johnson v. City of Oakland, California

Filing 61

ORDER TO PERMIT CONTINUED DEPOSITIONS AFTER DISCOVERY CUTOFF re 59 . Signed by Judge Elizabeth D. Laporte on 11/10/10. (lmh, COURT STAFF) (Filed on 11/10/2010)

Johnson v. City of Oakland, California

Doc. 61

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SHEILA Y. THOMAS (SB No. 161403) Law Offices of Sheila Thomas 5260 Proctor Avenue Oakland, CA 94618 Telephone: [phone] Facsimile: [phone] [e-mail] Attorney for Plaintiff Debra Taylor Johnson UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

DEBRA TAYLOR JOHNSON,

) ) Plaintiff, ) ) v. ) ) CITY OF OAKLAND, CA, ) ) Defendant. ) ) ) ) ) ____________________________________)

Case No. C09-05157 RS (EDL)

STIPULATION BETWEEN THE PARTIES TO PERMIT CONTINUED DEPOSITIONS OF HOWARD JORDAN AND DEBRA TAYLOR JOHNSON AFTER DISCOVERY CUTOFF AND ORDER THEREON

Whereas, Assistant Chief of the Oakland Police Department, Howard Jordan, was deposed by Plaintiff on October 26, 2010; Whereas, following the deposition of Assistant Chief Jordan, and while searching for documents responsive to Plaintiff's Third Request for Production of Documents, Defendant located additional documents which were produced to Plaintiff on October 29, 2010; Whereas, upon receipt of these documents, Plaintiff requested further deposition time with Assistant Chief Jordan; Whereas, Defendant City of Oakland has agreed to permit Plaintiff an opportunity to further depose Assistant Chief Jordan to ask questions related to the additional documents produced, within the time limit remaining for his deposition under Fed Rule of Civ. Proc. 30(d); Whereas, Assistant Chief Jordan is not available for deposition prior to the discovery STIPULATION 1
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cut-off date of November 11, 2010 on a date when Plaintiff's counsel is also available; Whereas, Defendant offered the following dates for the continued deposition of Assistant Chief Jordan: November 11, 15 and 18, 2010; Whereas, the parties have agreed to schedule Assistant Chief. Jordan's deposition for November 15, 2010 beginning at 2:00 p.m.; FURTHERMORE, Whereas, on November 8, 2010, Judge Laporte granted Defendant's Motion to Compel further deposition testimony from Plaintiff for a further three and a half hours of testimony; and Whereas, the parties have agreed to schedule Ms. Johnson's deposition for November 15, 2010 beginning at 8:30 a.m.; The parties, Plaintiff Debra Taylor Johnson and Defendant City of Oakland, therefore, acting through their respective counsel, hereby stipulate that Plaintiff may continue the deposition of Howard Jordan on November 15, 2010 and that Defendant may continue the deposition of Debra Taylor Johnson on November 15, 2010.

IT IS SO STIPULATED. Dated: November 8, 2010 RENNE SLOAN HOLTZMAN SAKAI LLP

By:

_______/S/_____________________________ Steven Shaw Attorneys for Defendant City of Oakland

Dated: November 8, 2010

LAW OFFICES OF SHEILA THOMAS

By:

_______________/S/_____________________ Sheila Y. Thomas Attorney for Plaintiff Debra Taylor Johnson

STIPULATION 2

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

DATED: November 10, 2010

_________________________________________ ELIZABETH LAPORTE UNITED STATES DISTRICT COURT MAGISTRATE JUDGE

STIPULATION 3