Knudsen v. City and County of San Francisco et al
Filing
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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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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
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Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO,
JOHN MARTIN and BLAKE SUMMERS
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UNITED STATES DISTRICT COURT
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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.
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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):
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(1) The parties seek to continue these dates for the following reasons: Plaintiff filed an
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Amended Complaint on January 25, 2013, adding three new causes of action: gender discrimination;
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Stip. and Prop. Order Changing Deadlines
CASE NO. CV 12-1944 JST
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disability discrimination; and retaliation under the Fair Employment and Housing Act. The parties
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request additional time to conduct discovery on these claims. Furthermore, the parties agreed to
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withhold taking City witness depositions while they explored whether early settlement was possible.
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Unfortunately, it was not. Finally, Plaintiff’s counsel will be out of the office for the first three weeks
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of June 2013 on vacation. The City’s counsel is going on maternity leave beginning on or around June
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6, 2013. The short two month extension on the dates below will give the new Deputy City Attorney
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assigned to the case a chance to transition into this case and prepare the City’s anticipated motion for
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summary judgment.
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(2) There have been no previous time modifications in the case.
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(3) Since this Court has vacated the current trial date of September 16, 2013, it is not
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anticipated that the requested time modification will adversely impact the schedule of this case. For
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the Court’s information, the parties intend to propose a trial date of November 18, 2013 in their Joint
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Case Management Conference Statement, which the Court has ordered filed by May 20, 2013. The
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parties believe the dates below would be appropriate for a November 2013 (or later) trial date.
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Accordingly, the parties stipulate to the following time modifications on Judge Illston’s August
8, 2012 Pretrial Preparation Order:
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Non-Expert Discovery Cutoff:
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Existing Date: May 10, 2013
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New Date: July 9, 2013
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Designation of Experts:
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Existing Date: June 7, 2013
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New Date: August 7, 2013
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Dispositive Motions Shall be Filed by:
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Existing Date: June 14, 2013
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Opposition Due: June 28, 2013
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Reply Due: July 5, 2013.
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New Date: August 16, 2013
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Opposition Due: August 30, 2013
Stip. and Prop. Order Changing Deadlines
CASE NO. CV 12-1944 JST
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Reply Due: September 6, 2013
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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
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By:________/s/___________________
LISA BERKOWITZ
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO,
JOHN MARTIN, and BLAKE SUMMERS
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PROPOSED ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated: March 28, 2013
___________________________
HON. JON S. TIGAR
United States District Judge
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Stip. and Prop. Order Changing Deadlines
CASE NO. CV 12-1944 JST
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