Jefferson v. City of Fremont et al

Filing 84

STIPULATION AND ORDER re 83 Stipulation and Order extend deadline for dispositive motions, etc. Discovery due by 5/30/2014. Dispositive Motion Hearing reset for 7/10/2014 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Hon. Edward M. Chen. (bpf, COURT STAFF) (Filed on 3/27/2014) Modified on 3/27/2014 (bpf, COURT STAFF).

Case3 :12-cv-00926-EMC Document82 Filed03/25/14 Pagel of 4

2
3

4

5
6

7
8

9
10

II
12
13
14
15
16

Gregory M. Fox, State Bar No. 070876
Ilana Kohn, State Bar No . 203389 (Of Counsel)
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Harvey E. Levine, Esq., State Bar No . 61880
City Attorney City of Fremont
3300 Capitol A venue
PO Box 5006
Fremont, CA 94537-5006
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CITY OF FREMONT, FREMONT TENNIS CENTER,
JEFF GONCE, JOE GRECH, ANNABELLE HOLLAND
and KELLY KING
Angela L. Morgan, State Bar No. 208585
MORGAN-LOGAN LAW GROUP
2603 Camino Ramon, Suite 200
San Ramon, CA 94583
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
WALTER JEFFERSON

17
UNITED STATES DISTRICT COURT

18
19
20

WALTERJEFFERSON,

21

NORTHERN DISTRICT OF CALIFORNIA
Case No.3: 12-cv-00926 EMC

Plaintiff,

22

v.

23

THE CITY OF FREMONT, FREMONT
TENNIS CENTER, JEFF GONCE, and Does 1
through 10, inclusive,

24
25

STIPULATION OF COUNSEL AND
ORDER TO EXTEND DEADLINE
FOR DISPOSITIVE MOTIONS AND NONEXPERT DISCOVERY CUT-OFF

· [P~]

Defendants.

Hon. Edward M. Chen

26
27
28
STIPULATION OF COUNSEL AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR DISPOSITIVE
MOTIONS AND NON-EXPERT DISCOVERY CUT-OFF

Case3:12-cv-00926-EMC Document82 Filed03/25/14 Page2 of 4

Defendants City of Fremont, a municipal public entity on behalf of itself and the Fremont Tennis

2

Center and Jeff Gonce, and Plaintiff Walter Jefferson hereby submit the following Stipulation and

3

Proposed Order extending the time for dispositive motions and non-expert discovery cut-off.

4

WHEREAS on July 12, 2013, the Court issued a Case Management and Pre-Trial Order for Jury

5

Trial ("Order"). Pursuant to the Order, the parties were to complete non-expert discovery by March 20,

6

2014, and the last day for dispositive motions to be heard was June 12, 2014 .

7

WHEREAS on February 20, 2014, at the Joint Status Conference, the parties notified the Court

8

that plaintiff intended to take the deposition of Jeff Gonce and that Mr. Gonce's deposition could not be

9

completed before the March 20, 2014 discovery cut-off deadline;

10

WHEREAS the parties have met and conferred and agreed that plaintiff will take the deposition

11

of Jeff Gonce in Reno on May 28, 2014. The defendants also anticipate taking the depositions of Paul

12

Concepcion and Sarah Robinson before May 28, 20 14;

13

WHEREAS the parties have agreed that the last day for dispositive motions to be heard should be

14

moved to July 31 , 2014, in order to complete the above depositions and allow sufficient time to brief said

15

motions.

16

IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:

17

The time to complete non-expert discovery shall be extended to May 30, 2014. The last day for

18
19

dispositive motions to be heard shall be extended to July 31 , 2014 at 1:30 p.m.
SO STIPULATED.

20
21

Dated: March 20, 20 14

BERTRAND, FOX & ELLIOT

22
23
24
25

26
27

By: Is/ !lana Kahn
Gregory M. Fox
Ilana Kahn (Of Counsel)
Attorneys for Defendants
CITY OF FREMONT, FREMONT TENNIS
CENTER, JEFF GONCE, JOE GRECH,
ANNABELLE HOLLAND and KELLY KING

28
2
STIPULATION OF COUNSEL AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR DISPOSITIVE
MOTIONS AND NON-EXPERT DISCOVERY CUT-OFF

Case3 :12-cv-00926-EMC Document82 Filed03/25/14 Page3 of 4

Dated: March 25, 2014

MORGAN LOGAN LAW GROUP

2
3
4
5

/s/
Angela L. Morgan
Attorney for Plaintiff
WALTER JEFFERSON

By:

6
7
8
9
10
II

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
STIPULATION OF COUNSEL AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR DISPOSITIVE
MOTIONS AND NON-EXPERT DISCOVERY CUT-OFF

Case3:12-cv-00926-EMC Document82 Filed03/25/14 Page4 of 4

•

CERTIFICATE OF CONCURRENCE
2

I, Ilana Kohn, declare:

3

Pursuant to Local Rule No. 5-1 (i)(3) I have obtained the concurrence of all other parties in the

4

filing of this document, which shall serve in lieu of their signatures on the documents.

5
6

I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct and that this declaration is executed at San Francisco, California, on March 20, 2014.

7

Is/

8

lLANA KOHN, Esq.

9
10
11

ORDER

12
13
14

Pursuant to the above Stipulation of the parties by and through their respective counsel of record,
it is hereby ORDERED as follows:

15

1.

The time to complete non-expert discovery shall be extended to May 30, 2014.

16

2.

The last day for dispositive motions to be heard shall be extended to July

17

10

f1, 2014 at 1:30

p.m.

18

19

IT IS SO ORDERED.

20
21

22

Dated: Marchtk_, 2014
EDWARDM. CHEN
UNITED STATES DISTRICT COURT JUDGE

23
24
25

26
27

28
4
STIPULATION OF COUNSEL AND [PROPOSED] ORDER TO EXTEND DEADLINE FOR DISPOSITIVE
MOTIONS AND NON-EXPERT DISCOVERY CUT-OFF