Molieri et al v. County of Marin et al

Filing 32

ORDER RE: STIPULATION REQUESTING CHANGE OF BRIEFING SCHEDULE, STATUS CONFERENCE, PRETRIAL CONFERENCE AND TRIAL DATE. The expert discovery cutoff is extended to February 14, 2012. The deadline to file dispositive motions is extended to March 2, 2012. The Status Conference is continued to March 16, 2012, with a joint statement due by March 9, 2012. The last date to meet and confer for pretrial disclosures is extended to April 16, 2012. The pretrial conference is continued to May 22, 2012. The trial is continued to June 4, 2012. Signed by Judge Maxine M. Chesney on January 30, 2012. (mmclc1, COURT STAFF) (Filed on 1/30/2012)

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JOHN L. BURRIS, SBN 69888
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, CA 94621-1939
Tel: [phone],
Fax: [phone]
Attorneys for Plaintiffs Danilo Martin Molieri
and Daniel Steven Molieri.

PATRICK K. FAULKNER, COUNTY COUNSEL
Renee Giacomini Brewer, SBN 173012
3501 Civic Center Drive, Room 275
San Rafael, CA 94903
Tel.: [phone], Fax: [phone]
Attorney(s) for the Defendants County of Marin,
Scardina, Richardson, Bondanza.

DENNIS J. HERRERA, CITY ATTORNEY
Michael Gerchow, SBN 245706
Fox Plaza
1390 Market Street, Sixth Floor
San Francisco, CA 94102
Tel.: [phone]; Fax: [phone]

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Attorneys for Defendants City and County of San Francisco,
Cox and O’Malley.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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DANILO MARTIN MOLIERI and
DANIEL STEVEN MOLIERI,

ORDER RE:
Plaintiffs,

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Case No.: CV 10 5430 MMC

v.
COUNTY OF MARIN, SCARDINA,
RICHARDSON, BONDANZA, CITY AND
COUNTY OF SAN FRANCISCO, COX,
O’MALLEY; and Does 1-25, inclusive,

STIPULATION AND ORDER REQUESTING
CHANGE OF BRIEFING SCHEDULE,
STATUS CONFERENCE, PRETRIAL
CONFERENCE AND TRIAL DATE,
Civil Local Rule 7-11
Honorable Maxine M. Chesney

Defendants.
By this pleading, Plaintiff Danilo Martin Molieri and Daniel Steven Molieri (Plaintiffs”) and

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Defendants County of Marin, Scardina and Richardson (collectively, “COM Defendants”) and City and

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County of San Francisco, Cox and O’Malley (collectively, “City and County Defendants”), by and through

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their respective counsel, hereby stipulate and agree that this Court’s Pre-Trial Preparation dates be modified

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and changed as follows:

Request and Stipulation to Continue Pre-Trial and Trial Dates
CV 10-05430 MMC
49736

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1. Expert Discovery to close on February 14, 2012;

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2. Dispositive Motions to be filed by March 13, 2012;

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3. Further Status Conference on March 30, 2012 with joint statements due by March 23, 2012.

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4. Last date to meet and confer for pre-trial disclosures: April 27, 2012;

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5. Pre-trial disclosures due: May 15, 2012;

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6. Pre-Trial Conference: June 5, 2012;

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7. Trial: June 19, 2012.

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Good cause exists for the rescheduling because: (1) Plaintiffs have disclosed five experts and two disclosed

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experts are not available for depositions before the current close of expert discovery, January 27, 2012; and,

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(2) the parties require four weeks after expert depositions are completed prior to filing Summary Judgment

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Motions so that deposition transcripts will be completed for inclusion in said Motions. All parties agree to

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continue the pre-trial schedule as indicated.

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IT IS SO STIPULATED.

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Date: January 19, 2012

by:___________________-s-_______________
John L. Burris, Attorney for Plaintiffs

Date: January 19, 2012

by:__________________-s-_________________
Renee Giacomini Brewer, Attorney for Defendants
County of Marin, Scardina Richardson, Bondanza

Date: January 19, 2012

by:___________________-s-_______________
Michael Gerchow, Attorney for Defendants
Cox and O’Malley

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[PROPOSED] ORDER

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Based on the foregoing Stipulation and for good cause shown, the Court hereby accepts the Parties’

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Stipulation and ORDERS the following Pre-Trial Schedule: in part, the requested trial date of June 19,

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2012 not being available:

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1. Expert Discovery to close on February 14, 2012;

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2. Dispositive Motions to be filed by March 13, 2012; March 2, 2012;
Request and Stipulation to Continue Settlement Conference Date
CV103863WHA (JCS)
49736.doc

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March 16, 2012
March 9, 2012;
3. Further Status Conference on March 30, 2012 with Joint Statements due by March 23, 2012.

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4. Last date to meet and confer for pre-trial disclosures: April 27, 2012; April 16, 2012;

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5. Pre-trial disclosures due: May 15, 2012; May 1, 2012;

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6. Pre-Trial Conference: June 5, 2012; May 22, 2012; and

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7. Trial: June 19, 2012. June 4, 2012.

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IT IS SO ORDERED.

Dated: January 30, 2012

______________________________________________
THE HONORABLE MAXINE M. CHESNEY

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Request and Stipulation to Continue Settlement Conference Date
CV103863WHA (JCS)
49736.doc

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