Dickerson v. City of Oakland et al

Filing 38

ORDER GRANTING 37 Stipulation FOR EXTENSION OF TIME TO DISCLOSE EXPERTS AND EXPERT REPORTS; AND TO EXTEND TIME TO COMPLETE EXPERT DISCOVERY. CLOSE OF EXPERT DISCOVERY: 11/3/2011. Replies due by 8/24/2011. Motion Hearing set for 10/21/2011 09:00 PM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge JEFFREY S. WHITE on 8/3/11. (jjoS, COURT STAFF) (Filed on 8/3/2011)

Case3:10-cv-00435-JSW Document37

Filed08/02/11 Page1 of 3

JOHN L. BURRIS, Esq./ State Bar # 69888
LAW OFFICES OF JOHN L. BURRIS
7677 Oakport Street, Suite 1120
Oakland, CA 94621
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
GAYLA B. LIBET, Esq./ State Bar # 109173
LAW OFFICES OF GAYLA B. LIBET
486 41st Street, Suite 3
Oakland, CA 94609
Telephone and Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff
ARLENE M. ROSEN/ State Bar # 100160
Senior Deputy City Attorney
OAKLAND CITY ATTORNEY’S OFFICE
One Frank Ogawa Plaza, Sixth Floor
Oakland, CA 94612
Telephone: [phone]
Facsimile: [phone]
E-Mail:
[e-mail]

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

DESMOND J. DICKERSON,

Action No. C-10-00435-JSW

Plaintiff,

STIPULATION AND PROPOSED ORDER FOR
EXTENSION OF TIME TO DISCLOSE EXPERTS
AND EXPERT REPORTS; AND TO EXTEND TIME
TO COMPLETE EXPERT DISCOVERY

vs.
CITY OF OAKLAND, a municipal orporation;
WAYNE G. TUCKER, in his capacity as Chief
of Police for CITY OF OAKLAND; JASON
MITCHELL, JOSEPH FORMAN, JASON FONG,
individually, and in their capacity as police officers
for CITY OF OAKLAND; and, DOES 1-25,
inclusive,
Defendants.

/

STIPULATION
All parties to this action stipulate and agree, by and through their respective counsel,
as follows:

STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO DISCLOSE EXPERTS
AND EXPERT REPORTS;
AND EXPERT REPORTS; AND TO EXTEND TIME TO COMPLETE EXPERT DISCOVERY

1

Case3:10-cv-00435-JSW Document37

Filed08/02/11 Page2 of 3

1. That the following good cause exists for extending the time for disclosure of expert witnesses
and expert reports; for extending the time for expert discovery to be completed; and for extending the
cut-off date for hearing of dispositive motions;
2. Judge Larson was originally the Magistrate Judge with whom there was to be a Settlement
Conference in this case. It was scheduled for on August 27, 2011. Since the retirement of Judge
Larson from this Court, Magistrate Judge Jacqueline Scott Corley has been assigned as the Magistrate
Judge who will schedule and preside at Settlement Conference in this case. The date of
September 2, 2011 has been selected for the Settlement Conference;
3. By extending the time for disclosure of expert witnesses and expert reports; and extending the
time for expert discovery to be completed, the parties may not have to bear the cost of retaining
experts, should the case settle prior to the requested new extended dates for expert disclosure and
discovery;
4. As set forth in the Court’s Order, dated 5-25-11, the Pretrial Conference is scheduled for
11-14-11 at 2:00 p.m., and the scheduled date for Trial is 12-5-11 at 8:00 a.m.. Therefore, the parties’
request for extension of deadlines should not interfere with the presently scheduled pretrial and trial
dates set by the Court; and,
5. For all the good cause reasons stated above, the parties respectfully request, that the following
dates set forth in the Court’s Order, dated 5-25-11, be extended, as follows:
(A) That the date for disclosure of expert witnesses and expert reports be extended from
August 3, 2011 to October 12, 2011;
(B) That the cut-off date for completion of expert discovery be extended from August 17, 2011
to November 3, 2011; and,
(C ) That the last date to hear dispositive motions be extended from September 9, 2011 at 9:00
a.m. to October 20, 2011.

October 21, 2011 at 9:00 a.m.

LAW OFFICES OF GAYLA B. LIBET

Dated:

8-2-11

By: /s/

Gayla B. Libet, Esq.
GAYLA B. LIBET, Esq.
Attorneys for Plaintiff

STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO DISCLOSE EXPERTS
AND EXPERT REPORTS;
AND EXPERT REPORTS; AND TO EXTEND TIME TO COMPLETE EXPERT DISCOVERY

2

Case3:10-cv-00435-JSW Document37

Filed08/02/11 Page3 of 3

LAW OFFICES OF JOHN L. BURRIS

Dated:

8-2-11

By: /s/

John L. Burris
JOHN L. BURRIS, Esq.
Attorneys for Plaintiff

OFFICE OF THE OAKLAND CITY ATTORNEY

Dated:

8-2-11

By:

/s/

Arlene M. Rosen, Esq.
ARLENE M. ROSEN, Esq.
Attorneys for Defendants

ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated:

August 2, 2011
HONORABLE JEFFREY S. WHITE
United States District Court Judge

STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO DISCLOSE EXPERTS
AND EXPERT REPORTS;
AND EXPERT REPORTS; AND TO EXTEND TIME TO COMPLETE EXPERT DISCOVERY

3