Johnson et al v. County of Alameda et al

Filing 33

***FILED IN ERROR***PLEASE SEE #34****STIPULATION AND ORDER CONTINUING DEADLINE TO COMPLETE DISCOVERY AND TO HEAR PRETRIAL MOTIONS AS MODIFIED BY THE COURT. Signed by Judge Richard Seeborg on 2/28/11. (cl, COURT STAFF) (Filed on 2/28/2011) Modified on 2/28/2011 (cl, COURT STAFF).

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Johnson et al v. County of Alameda et al Doc. 33 *E-Filed 2/28/11* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiffs, CYNTHIA JOHNSON and JAMONT JOHNSON ("Plaintiffs") and Defendants, COUNTY OF ALAMEDA, ALAMEDA COUNTY SHERIFF'S OFFICE, ALAMEDA COUNTY SHERIFF'S OFFICE DETENTION AND CORRECTION DIVISION, and DEPUTY SHERIFF KEITH W. GILKERSON ("Defendants"), by and through their respective attorneys of record, hereby stipulate as follows: 1 STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO COMPLETE DISCOVERY AND TO HEAR PRE-TRIAL MOTIONS Johnson v. County of Alameda, et al., Case No.: CV-101437-RS Dockets.Justia.com JAMES MCMANIS (40958) MARWA ELZANKALY (206658) RUBY H. KAZI (243872) McMANIS FAULKNER A Professional Corporation 50 West San Fernando Street, 10th Floor San Jose, California 95113 Telephone: 408-279-8700 Facsimile: 408-279-3244 Email: rkazi@mcmanislaw.com Attorneys for Plaintiffs, CYNTHIA JOHNSON and JAMONT JOHNSON UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CYNTHIA JOHNSON and JAMONT JOHNSON, as individuals, Plaintiffs, Case No. CV-101437 RS STIPULATION CONTINUING DEADLINE TO COMPLETE DISCOVERY AND TO HEAR PRETRIAL MOTIONS AS MODIFIED BY THE COURT vs. COUNTY OF ALAMEDA, a public entity, ALAMEDA COUNTY SHERIFF'S OFFICE, a department of the County of Alameda, ALAMEDA COUNTY SHERIFF'S OFFICE DETENTION AND CORRECTION DIVISION, a department of the County of Alameda, DEPUTY SHERIFF KEITH W. GILKERSON, an individual, and DOES 1-50, inclusive, Defendants. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. On January 10, 2011, the Court approved the parties' stipulation to complete all non-expert discovery on or before April 29, 2011 and that all pre-trial motions be heard no later than June 29, 2011. 2. The parties are in the process of conducting discovery and have stipulated to a settlement conference in an effort to resolve this case. Subsequent to the parties' stipulation continuing the deadlines to complete non-expert discovery, the Court granted the parties' request to be referred to Magistrate Judge Joseph Spero for a settlement conference. In light of the date ordered for the settlement conference (April 7, 2011), the parties took key depositions of Plaintiff Cynthia Johnson and Defendant Deputy Keith Gilkerson, but in the interest of enhancing settlement prospects, agreed to defer other non-essential discovery until after the settlement conference. This will prevent the parties from incurring substantial fees and costs prior to settlement. 3. The parties have agreed to continue the deadline to complete all non-expert discovery from April 29, 2011 to June 15, 2011. 4. experts. 5. 6. The parties have also agreed that expert discovery shall close on June 30, 2011. In light of these continued dates, the parties have further agreed to continue the The parties have further agreed that May 13, 2011 shall be the last day to disclose deadline to hear all potentially dispositive pre-trial motions from June 29, 2011 to July 8, 2011. IT IS SO STIPULATED. DATED: February 25, 2011 McMANIS FAULKNER /s/ Ruby H. Kazi JAMES McMANIS RUBY H. KAZI Attorneys for Plaintiffs, CYNTHIA JOHNSON and JAMONT JOHNSON 2 STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO COMPLETE DISCOVERY AND TO HEAR PRE-TRIAL MOTIONS Johnson v. County of Alameda, et al., Case No.: CV-101437-RS 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: February 25, 2011 BERTRAND, FOX & ELLIOT /s/ Michael C. Wenzel MICHAEL C. WENZEL Attorneys for Defendants, COUNTY OF ALAMEDA, ALAMEDA COUNTY SHERIFF'S OFFICE, ALAMEDA COUNTY SHERIFF'S OFFICE DETENTION AND CORRECTION DIVISION, and DEPUTY SHERIFF KEITH W. GILKERSON ORDER GOOD CAUSE APPEARING THEREFORE, and the parties having stipulated to same, the parties' stipulation is hereby APPROVED. The deadline to complete all non-expert discovery is continued from April 29, 2011 to June 15, 2011. The deadline to disclose experts is May 13, 2011 and expert discovery shall close on June 30, 2011. The deadline to hear all potentially dispositive pre-trial motions is continued from June 29, 2011 to July 8, 2011. IT IS SO ORDERED. 2/28/11 DATED: ____________________ _________________________________ UNITED STATES DISTRICT JUDGE 3 STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO COMPLETE DISCOVERY AND TO HEAR PRE-TRIAL MOTIONS Johnson v. County of Alameda, et al., Case No.: CV-101437-RS

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