Molieri et al v. County of Marin et al

Filing 26

ORDER APPROVING STIPULATION TO EXTEND FACT DISCOVERY CUTOFF. The deadline for completing fact discovery is modified to permit the depositions and discovery specified in the parties' stipulation, to be completed no later than December 23, 2011. Signed by Judge Maxine M. Chesney on December 1, 2011.(mmclc1, COURT STAFF) (Filed on 12/1/2011)

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JOHN L. BURRIS, ESQ. SBN 69888
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for plaintiffs
DANILO MARTIN MOLIERI and
DANIEL STEVEN MOLIERI

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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DANILO MARTIN MOLIERI and
DANIEL STEVEN MOLIERI

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Plaintiff,

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vs.
COUNTY OF MARIN, et al.
Defendants.

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Case No.: C10-05430 MMC
Complaint filed: 12/1/10
STIPULATION AND REQUEST TO
EXTEND FACT DISCOVERY CUTOFF;
(PROPOSED) ORDER

STIPULATION
Plaintiffs filed their complaint on December 1, 2010 and all parties were served and have

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answered. The court ordered fact discovery to be completed by December 2, 2011. Although

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the parties have been diligent and cooperative in conducting discovery, additional discovery is

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needed to prepare the case for resolution. The specific discovery items to be conducted are the

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depositions of San Francisco police officers Heppler and Zhang, two depositions of “persons

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STIPULATION TO MODIFY FACT DISCOVERY DEADLINE

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most knowledgeable, and the psychological examination of plaintiff Daniel Steven Molieri

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related to his damages claim (emotional distress). The proposed discovery extension through

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December 23, 2011 is not expected to affect or impose upon any other aspect of the court’s

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scheduling order, including expert discovery deadlines.

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WHEREFORE the parties, by and through their respective counsel stipulate, agree and
request that, subject to approval and order of the court, the deadline for completing the abovereferenced discovery will be extended to and including December 23, 2011.

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LAW OFFICES OF JOHN L. BURRIS

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Dated: November 30, 2011

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/S/JOHN L. BURRIS _________
Attorneys for Plaintiffs
DANILO MARTIN MOLIERI and
DANIEL STEVEN MOLIERI
PATRICK K. FAULKNER,
COUNTY COUNSEL

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Dated: November 30, 2011

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/S/RENEE GIACOMINI BREWER _________
Attorneys for Defendant
COUNTY OF MARIN
DENNIS J. HERRERA,
CITY ATTORNEY

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Dated: November 30, 2011

/S/MICHAEL GERCHOW ______________
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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STIPULATION TO MODIFY FACT DISCOVERY DEADLINE

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ORDER

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The court having considered the stipulation of the parties and good cause

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appearing,
IT IS ORDERED that the deadline for completing fact discovery is modified to permit

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the depositions and discovery specified in the parties stipulation to be completed no later than

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December 23, 2011. The court’s scheduling order is not modified in any other particular.

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Dated: December 1, 2011

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UNITED STATES DISTRICT JUDGE

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STIPULATION TO MODIFY FACT DISCOVERY DEADLINE

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