Knudsen v. City and County of San Francisco et al

Filing 42

STIPULATION AND ORDER CHANGING DEADLINES IN PRETRIAL PREPARATION ORDER. Signed by Judge Jon S. Tigar on March 28, 2013. CORRECTION OF DOCKET # 41 . (wsn, COURT STAFF) (Filed on 3/28/2013)

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1 2 3 4 5 6 DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH SALVESON, State Bar #83788 Chief Labor Attorney LISA B. BERKOWITZ, State Bar #167657 Deputy City Attorney Fox Plaza 1390 Market Street, 5th Floor San Francisco, California 94102-5408 Telephone: (415) 554-3825 Facsimile: (415) 554-4248 E-Mail: lisa.berkowitz@sfgov.org 7 8 9 Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO, JOHN MARTIN and BLAKE SUMMERS 10 11 UNITED STATES DISTRICT COURT 12 13 14 15 16 17 18 19 NORTHERN DISTRICT OF CALIFORNIA SONYA KNUDSEN, Plaintiff, vs. CITY AND COUNTY OF SAN FRANCISCO, SAN FRANCISCO INTERNATIONAL AIRPORT, JOHN MARTIN, BLAKE SUMMERS, AND DOES 1 THROUGH 25, INCLUSIVE, Case No. CV 12-1944 JST STIPULATION AND PROPOSED ORDER CHANGING DEADLINES IN PRETRIAL PREPARATION ORDER [Civil L.R., Rule 6-2; 7-12] Defendants. 20 21 22 23 24 25 Plaintiff Sonya Knudsen and Defendants City and County of San Francisco (“City”), John Martin, and Blake Summers hereby submit the following Stipulation and Proposed Order continuing pretrial deadlines in the above-referenced case, pursuant to Northern District Civil L.R., Rules 6-2 and 7-12. Per Rule 6-2(a): 26 (1) The parties seek to continue these dates for the following reasons: Plaintiff filed an 27 Amended Complaint on January 25, 2013, adding three new causes of action: gender discrimination; 28 Stip. and Prop. Order Changing Deadlines CASE NO. CV 12-1944 JST 1 1 disability discrimination; and retaliation under the Fair Employment and Housing Act. The parties 2 request additional time to conduct discovery on these claims. Furthermore, the parties agreed to 3 withhold taking City witness depositions while they explored whether early settlement was possible. 4 Unfortunately, it was not. Finally, Plaintiff’s counsel will be out of the office for the first three weeks 5 of June 2013 on vacation. The City’s counsel is going on maternity leave beginning on or around June 6 6, 2013. The short two month extension on the dates below will give the new Deputy City Attorney 7 assigned to the case a chance to transition into this case and prepare the City’s anticipated motion for 8 summary judgment. 9 (2) There have been no previous time modifications in the case. 10 (3) Since this Court has vacated the current trial date of September 16, 2013, it is not 11 anticipated that the requested time modification will adversely impact the schedule of this case. For 12 the Court’s information, the parties intend to propose a trial date of November 18, 2013 in their Joint 13 Case Management Conference Statement, which the Court has ordered filed by May 20, 2013. The 14 parties believe the dates below would be appropriate for a November 2013 (or later) trial date. 15 16 Accordingly, the parties stipulate to the following time modifications on Judge Illston’s August 8, 2012 Pretrial Preparation Order: 17 Non-Expert Discovery Cutoff: 18 Existing Date: May 10, 2013 19 New Date: July 9, 2013 20 Designation of Experts: 21 Existing Date: June 7, 2013 22 New Date: August 7, 2013 23 Dispositive Motions Shall be Filed by: 24 Existing Date: June 14, 2013 25 Opposition Due: June 28, 2013 26 Reply Due: July 5, 2013. 27 New Date: August 16, 2013 28 Opposition Due: August 30, 2013 Stip. and Prop. Order Changing Deadlines CASE NO. CV 12-1944 JST 2 1 Reply Due: September 6, 2013 2 3 4 5 Dated: ___________/s/__________________ JOHN HOUSTON SCOTT, Esq. Scott Law Firm Attorney for Plaintiff SONYA KNUDSEN Dated: DENNIS J. HERRERA City Attorney ELIZABETH S. SALVESON Chief Labor Attorney LISA BERKOWITZ Deputy City Attorney 6 7 8 9 10 11 12 13 14 By:________/s/___________________ LISA BERKOWITZ Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO, JOHN MARTIN, and BLAKE SUMMERS 15 16 17 18 19 20 PROPOSED ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. 21 22 Dated: March 28, 2013 ___________________________ HON. JON S. TIGAR United States District Judge 23 24 25 26 27 28 Stip. and Prop. Order Changing Deadlines CASE NO. CV 12-1944 JST 3

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