Foster v. Berkeley Police Department et al

Filing 68

ORDER TO CONTINUE DEPOSITION OF DR. LISA LATTANZA BEYOND THE DISCOVERY CUT-OFF (tf, COURT STAFF) (Filed on 10/25/2011)

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Zach Cowan, City Attorney, SBN 96372
Matthew J. Orebic, Deputy City Attorney, SBN 124491
Lynne S. Bourgault, Deputy City Attorney, SBN 180416
BERKELEY CITY ATTORNEY’S OFFICE
2180 Milvia Street, Fourth Floor
Berkeley, CA 94704
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendants
CITY OF BERKELEY, DOUGLAS HAMBLETON,
ALEXANDER McDOUGALL and ERIK KEENE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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NADRA FOSTER,

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No. C10-03703 SI (ADR)

Plaintiff,

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v.

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BERKELEY POLICE DEPARTMENT; et
al.,

STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DEPOSITION
OF DR. LISA LATTANZA BEYOND THE
DISCOVERY CUT-OFF

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Defendants.
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The parties through their counsel herein stipulate that the deposition of Dr. Lisa Lattanza,

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a treating doctor for plaintiff, currently set for October 25, 2011 at 4:00 p.m. at UCSF Medical

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Center, 1500 Owens Street, First Floor, San Francisco, CA can be continued to November 22,

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2011 at 4:00 p.m. at the same location. The non-expert discovery cutoff is October 28, 2011.

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Defense counsel for City of Berkeley, Matthew Orebic, requests this continuance of the

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deposition to a date beyond the percipient witness discovery cutoff because (1) Mr. Orebic is

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needed at a medical procedure for his 88-year old mother that was recently scheduled on an

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expedited basis, (2) there is no other person or family member as appropriate as Mr. Orebic to

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transport and care for his mother on October 25, and (3) the next available date for Dr. Lattanza

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEPOSITION OF DR. LISA LATTANZA
BEYOND THE DISCOVERY CUT-OFF
NO. C 10-03703 SI (ADR)

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to give a deposition is November 22. Plaintiff’s counsel is concerned that parties do not have

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the authority to make such a stipulation, but is amenable due to human concerns.

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Dated: October 19, 2011

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Respectfully submitted:

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ZACH COWAN, City Attorney
MATTHEW J. OREBIC, Deputy City Attorney
LYNNE S. BOURGAULT, Deputy City Attorney

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By:

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/s/ Matthew J. Orebic
MATTHEW J. OREBIC
Attorneys for Defendants
CITY OF BERKELEY, , DOUGLAS
HAMBLETON, ALEXANDER McDOUGALL
and ERIK KEENE

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Dated: October 19, 2011

Respectfully submitted:

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By:
/s/ Arcolina Panto
ARCOLINA PANTO
Attorney for Plaintiff
NADRA FOSTER

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Dated: October 19, 2011

Respectfully submitted:

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NGO LEGAL GROUP, A Professional Corp.
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By:

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/s/ Steve Ngo
STEVE NGO
Attorney for Defendants
LOIS WITHERS, KPFA, and PACIFICA
FOUNDATION

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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10/24/11
Dated: _________________

________________________________________
HONORABLE SUSAN ILLSTON
Judge of the U.S. District Court

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEPOSITION OF DR. LISA LATTANZA
BEYOND THE DISCOVERY CUT-OFF
NO. C 10-03703 SI (ADR)