Retiree Support Group of Contra Costa County v. Contra Costa County

Filing 89

STIPULATION AND ORDER re 88 STIPULATION WITH PROPOSED ORDER Extending Case Deadlines filed by Retiree Support Group of Contra Costa County. Signed by Judge Jon S. Tigar on January 16, 2014. (wsn, COURT STAFF) (Filed on 1/16/2014)

1 LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
JEFFREY LEWIS, SBN 066587
2 [e-mail]
BILL LANN LEE, SBN 108452
3 [e-mail]
ANDREW LAH, SBN 234580
4 [e-mail]
NINA WASOW, SBN 242047
5 [e-mail]
DARIN RANAHAN, SBN 273532
6 [e-mail]
476 9th Street
7 Oakland, CA 94607
Telephone:
[phone]
8 Facsimile:
[phone]
9 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
10 [e-mail]
STEPHEN B. PECK, SBN 72214
11 [e-mail]
JANE M. FEDDES, SBN 282117
12 [e-mail]
425 Market Street, 26th Floor
13 San Francisco, California 94105
Telephone:
[phone]
14 Facsimile:
[phone]

15 Attorneys for Defendant
CONTRA COSTA COUNTY
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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20 RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY,
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Plaintiff,
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v.
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CONTRA COSTA COUNTY,
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Defendant.
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CASE NO. C 12-00944 JST
STIPULATION EXTENDING CASE
DEADLINES AND [PROPOSED] ORDER
Judge: Hon. Hon. Jon S. Tigar

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WHEREAS, the current Scheduling Order provides the indicated case deadlines (Dkt. 77);
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WHEREAS, the parties are in the midst of exchanging documents in agreed rolling
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6039202.2

C 12-00944 JST
STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

1 productions, and additional documents remain to be produced;
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WHEREAS, Plaintiff Retiree Support Group of Contra Costa County (“Plaintiff”) may

3 wish to amend the allegations in its Second Amended Complaint based on documents produced
4 and to be produced, and Defendant Contra Costa County (“Defendant”) will amend its Answer by
5 May 15, 2014 if Plaintiff does not file an amended complaint, or file its response by June 4, 2014
6 if Plaintiff files an amended complaint;
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WHEREAS, the parties wish to continue to meet and confer on other discovery matters

8 and resolve as many discovery issues as possible without court intervention;
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WHEREAS, the parties wish to shift case deadlines and the trial date back for ninety (90)

10 days to allow the parties additional time to complete their productions of documents, to permit the
11 filing of amended pleadings, and to more efficiently manage their respective cases;
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NOW THEREFOR, the parties, by and through their respective counsel of record, hereby

13 stipulate and agree to continue the Case Management Conference set for January 29, 2014 to May
14 28 at 2 p.m. and to the following case deadlines pursuant to Federal Rule of Civil Procedure 16

15 and Civil Local Rule 16-10:
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Event

Deadline

Deadline for the parties to complete
document production [First RFPs]

3/31/14

Deadline for Plaintiff to amend
Complaint and, if Plaintiff does not
amend Complaint, for Defendant to
file an amended Answer

5/15/14

Deadline for Defendant to file a
response if Plaintiff files an amended
Complaint

6/4/14

Fact discovery cut-off

11/3/14

Expert disclosures

12/8/14

Expert rebuttal

12/22/14

Expert discovery cut-off

1/8/15

Deadline to file dispositive motions

1/29/15

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6039202.2

-2STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST

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Pretrial conference statement due

4/6/15

Pretrial conference

4/16/15 4/17/15 at 2:00 p.m. or such other
date available on the Court’s schedule

Bench trial

5/4/15 at 8:30 a.m. or such other date
available on the Court's trial schedule

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IT IS SO STIPULATED.

7 DATED: January 15, 2014

LEWIS, FEINBERG, LEE, RENAKER &
JACKSON, P.C.

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By:

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DATED: January 15, 2014

/s/
NINA WASOW
Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY
HANSON BRIDGETT LLP

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By:

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/s/
RAYMOND F. LYNCH
Attorneys for Defendant
CONTRA COSTA COUNTY

IT IS SO ORDERED.
Dated: January 16, 2014
HONORABLE JON S. TIGAR
United States District Court Judge

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6039202.2

-3STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST

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SIGNATURES UNDER GENERAL ORDER NO. 45

2 Pursuant to General Order No. 45 of the United States District Court, Northern District of
3 California, I, Nina Wasow—the ECF User whose User ID and Password are used in the filing of
4 this document—hereby attest that the concurrence to the filing of this document has been obtained
5 from each of the other signatories to this document.
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/s/
Nina Wasow

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6039202.2

-4STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST