Curtis v. City of Oakland et al

Filing 41

ORDER extending discovery deadline (tf, COURT STAFF) (Filed on 6/20/2011)

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MICHAEL W. FOSTER (State Bar No. 127691)
[e-mail]
MADELYN G. JORDAN DAVIS (State Bar No. 181771)
[e-mail]
FOSTER EMPLOYMENT LAW
3000 LAKESHORE AVENUE
OAKLAND, CA. 94610
TELEPHONE: [phone]
FACSIMILE: [phone]
Attorneys for Defendants
CITY OF OAKLAND, JENNIFER RAY,
JOSEPH TORRES, JOHN FARRELL AND
GERALD A. SIMON

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
3000 Lakeshore Avenue
Oakland, California 94610

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RONALD EL-MALIK CURTIS,

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Plaintiff,

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vs.
CITY OF OAKLAND, JENNIFER RAY,
JOSEPH TORRES, JOHN FARRELL
AND GERALD A. SIMON, CHIEF, and
DOES 1 through 15,

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Defendants.

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Case No. C10-00358-SI
Date Action Filed:
Jan. 6, 2010
Current Trial Date:
Sept. 6, 2011
Current Final Pretrial Con: Aug. 23, 2011
STIPULATION AND JOINT REQUEST
FOR AN ORDER BY ALL PARTIES
EXTENDING THE DEADLINE FOR
EXCHANGE OF FACT DISCOVERY

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1.

Defendants CITY OF OAKLAND, JENNIFER RAY, JOSEPH TORRES, JOHN

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FARRELL and GERALD A. SIMON (“Defendants”) and Plaintiff RONALD EL-MALIK CURTIS

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(“Plaintiff”) (hereinafter referred to collectively as “the parties”) hereby stipulate to extend the

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deadline for the exchange of fact discovery.

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STIPULATION BY ALL PARTIES TO EXTEND THE DEADLINE FOR FACT DISCOVERY

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In the interests of justice, and for good cause, the parties agree to extend fact

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discovery in light of counsel for Defendants, Madelyn Jordan-Davis’ unexpected medical leave. Ms.

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Davis is the lead counsel for Defendants and due to her earlier unplanned absence there has been a

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significant delay in the exchange of discovery. The parties hereby agree that if discovery closed on

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April 1, 2011 then the trial will not be able to proceed on its full merits, as much of the factual

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investigation and discovery that is necessary for both parties has not been completed. Accordingly,

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in the interest of justice, the parties hereby stipulate and respectfully request the Court enter an order

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extending the deadline for the exchange of fact discovery from April 1, 2011 to September 30, 2011.

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3000 Lakeshore Avenue
Oakland, California 94610

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IT IS SO STIPULATED.
Dated: June 6, 2011

PRICE AND ASSOCIATES

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/s/
Pamela Y. Price
Jacqueline Lindsey
Attorneys for Plaintiff
RONALD EL-MALIK CURTIS

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Dated: June 6, 2011

FOSTER EMPLOYMENT LAW

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/s/
Michael W. Foster
Madelyn G. Jordan-Davis
Attorneys for Defendants
CITY OF OAKLAND, OAKLAND FIRE
DEPARTMENT, JENNIFER RAY, JOSEPH
TORRES, JOHN FARRELL AND
GERALD A. SIMON

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STIPULATION BY ALL PARTIES TO EXTEND THE DEADLINE FOR FACT DISCOVERY

[PROPOSED] ORDER

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Having read and considered the Stipulation and Joint Request for an Order Extending the

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Discovery Deadline and GOOD CAUSE APPEARING therefore, IT IS HEREBY ORDERED that

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the discovery deadline be reset to September 30, 2011. Counsel for Defendants shall promptly serve

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a copy of this Order on Plaintiff’s counsel.

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DATED: 6/20/11
__________

___________________________
UNITED STATES DISTRICT JUDGE

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3000 Lakeshore Avenue
Oakland, California 94610

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STIPULATION BY ALL PARTIES TO EXTEND THE DEADLINE FOR FACT DISCOVERY