Sullivan et al v. City of San Rafael et al

Filing 43

ORDER by Magistrate Judge Maria-Elena James granting 42 Stipulation to continue date for disclosure of experts and disclosure of rebuttal experts. (rmm2S, COURT STAFF) (Filed on 3/25/2013)

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Thomas F. Bertrand, SBN 056560
Richard W. Osman, SBN 167993
BERTRAND, FOX & ELLIOT
2749 Hyde Street
San Francisco, Ca 94109
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendants
CITY OF SAN RAFAEL,
RYAN DEMARTA and RYAN COGBILL

Brian K. Gearinger, SBN 146125
GEARINGER LAW GROUP
825 Van Ness Ave., 4th Floor
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiffs
GREGORY L. SULLIVAN and
KOJI FUJITA

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James D. Rush, SBN 240284
LAW OFFICES OF JAMES D. RUSH, APC
7665 Redwood Boulevard, Suite 200
Novato, CA 94945
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiffs
GREGORY L. SULLIVAN and
KOJI FUJITA

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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GREGORY L. SULLIVAN and
KOJI FUJITA,
Plaintiffs,
v.

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CITY OF SAN RAFAEL, a government
entity; SAN RAFAEL POLICE
DEPARTMENT, a government entity;
RYAN DEMARTA, individually, and in
his capacity as police officer for the CITY
OF SAN RAFAEL; RYAN COGBILL,
individually, and in his capacity as police
officer for the CITY OF SAN RAFAEL;
and DOES 1 to 100,

Case No.: CV 12-01922 MEJ
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DATE FOR DISCLOSURE OF
EXPERTS AND DISCLOSURE OF
REBUTTAL EXPERTS

Defendants.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATE FOR EXPERT DISCLOSURES AND
DISCLOSURE OF REBUTTAL EXPERTS
Sullivan v. City of San Rafael, et al.
U.S.D.C. Northern District of CA Case No. CV-12-01922 MEJ

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The parties, by and through their respective counsel, hereby stipulate and request that the

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presently-scheduled March 29, 2013 Expert Disclosure date be continued to April 23, 2013, and the

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April 8, 2013 Rebuttal Expert Disclosure date be continued to May 3, 2013 based on the following:

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The last day to complete fact discovery in this matter is April 23, 2013.

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Multiple depositions are scheduled during the next several weeks and the parties intend to have

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their experts review and potentially include information from these depositions in their FRCP Rule 26

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reports. Moving the expert disclosure dates will accommodate this.

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Continuing the Expert Disclosure date and the Rebuttal Expert date will not affect any other
dates in this case.

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SO STIPULATED.
Dated: March 22, 2013

BERTRAND, FOX AND ELLIOT

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By: /s/ Richard W. Osman
Richard W. Osman
Attorneys for Defendants

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Dated: March 22, 2013

LAW OFFICE OF JAMES D. RUSH
By: /s/ James D. Rush
James D. Rush
Attorneys for Plaintiffs

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Dated: March 22, 2013

GEARINGER LAW GROUP
By: /s/ Brian K. Gearinger
Brian K. Gearinger
Attorneys for Plaintiffs

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATE FOR SUBMISSION OF JOINT STATEMENT OF
UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT
Sullivan v. City of San Rafael, et al.
U.S.D.C. Northern District of CA Case No. CV-12-01922 MEJ

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[PROPOSED] ORDER

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Having reviewed the stipulation of counsel herein, IT IS HEREBY ORDERED that the Expert

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Disclosure date is continued from March 29, 2013 to April 23, 2013 and the Rebuttal Expert date is

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continued from April 8, 2013 to May 3, 2013.

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IT IS SO ORDERED.

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March 25, 2013
DATED: ____________________

___________________________________
HONORABLE MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE DATE FOR SUBMISSION OF JOINT STATEMENT OF
UNDISPUTED MATERIAL FACTS IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT
Sullivan v. City of San Rafael, et al.
U.S.D.C. Northern District of CA Case No. CV-12-01922 MEJ