Smith v. Harrington et al

Filing 63

STIPULATION AND ORDER EXTENDING CASE SCHEDULE (MODIFIED): Re 62 Stipulation filed by Kim Craven, George R. Valenzuela, Sharon E. Liddell, Stephen Mayer, Santa Rosa City School District. Last Day for Dispositive Motions/Further Case Manage ment Conference set for 9/18/2014 at 9:30 AM in Courtroom C, 15th Floor, San Francisco. Jury Selection set for 2/17/2015 at 8:30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Jury Trial set for 2/17/2015 at 8: 30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Pretrial Conference set for 1/29/2015 at 1:30 PM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Jury Trial set for 2/18/2015 at 8:30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Jury Trial set for 2/19/2015 at 8:30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Jury Trial set for 2/20/2015 at 8:30 AM in Courtroom C, 15th Floor, San Francisco before Magistrate Judge Laurel Beeler. Signed by Magistrate Judge Laurel Beeler on 4/21/2014. (ls, COURT STAFF) (Filed on 4/21/2014)

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Thomas Allen Moore (SBN 148698)
Law Offices of Thomas A. Moore
401 Ajuna Court
Encinitas, CA 92024
Telephone: [phone]
Facsimile: [phone]
e-mail: [e-mail]
Attorney for Plaintiff,
Thomas E. Smith

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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) Case No.: C12-3533 LB (MEJ)
)
) STIPULATION AND [PROPOSED]
Plaintiff,
) ORDER EXTENDING CASE SCHEDULE
)
vs.
)
STEVEN HARRINGTON, PhD., Individually )
and in his official capacity as Superintendent )
)
of Schools, for Sonoma County Office of
)
Education; SHARON E. LIDDELL,
)
Individually and in her official capacity as
Superintendent of Santa Rosa City Schools; )
GEORGE R. VALENZUELA, Individually )
)
and in his official capacity as Compliance
)
Officer of Santa Rosa City Schools;
STEPHEN MAYER, Individually and in his )
official capacity as Principal, Proctor Terrace )
Elementary School, Santa Rosa City Schools; )
DEBRA SANDERS, Ed.D, Individually and in )
)
her official capacity as Director Special
)
Services, Santa Rosa City Schools; KIM
CRAVEN, M.S. and M.A., Individually and in )
)
his official capacity as Special Services
)
Offices, Santa Rosa City Schools, School
Psychologist; SANTA ROSA CITY SCHOOL )
)
DISTRICT, and DOES 1 through 100,
)
)
Defendants.
)
THOMAS E. SMITH,

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Whereas discovery that was recently scheduled by both parties to occur in the month of

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April and May had to be postponed due to the unexpected death of Plaintiff’s counsel’s father,

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and his resultant unavailability as he traveled to the East Coast to attend funeral services, and

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whereas the discovery already scheduled will need to occur in the month of May and possibly
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Smith v. Harrington, et al.,/Case #C12-3533 LB (MEJ)
Stipulation And [Proposed] Order Extending Case Schedule

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into early June, the parties hereto, by and through their respective counsel, hereby stipulate and

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request that the current case schedule be extended by 30 days.

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The reason for the requested extension is that the parties have not yet completed the

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necessary party and witness depositions. The parties now expect to have those depositions

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completed by the end of May or mid-June. Plaintiff has noticed ten (10) depositions, the

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maximum number allowed without leave of court, and defense counsel plans to notice at least

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three (3) depositions. The undersigned attorneys are working diligently to get these depositions

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scheduled in a coordinated and timely manner. Additionally, written discovery served by

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Plaintiff has necessitated an extension of time to respond to, which was granted at the request of

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defense counsel, and said written discovery will need to be obtained by Plaintiff’s counsel in

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preparation for the depositions currently scheduled.
Therefore, the parties respectfully request that the scheduling order for this case be

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extended by 30 days, as set forth in the proposed order below.
IT IS SO STIPULATED.

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Dated: April 16, 2014

THOMAS A. MOORE

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By:

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*/s/ Thomas A. Moore
Attorney for Plaintiff
*Mr. Moore gave his consent to e-file this
document

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Dated: April 16, 2014

HAAPALA, THOMPSON & ABERN, LLP

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By:

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/s/ Rebecca S. Widen
Rebecca S. Widen
Attorneys For Defendants
ORDER

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The Court having considered the parties’ stipulation, and good cause appearing, IT IS

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HEREBY ORDERED that the current case schedule be extended 30 days. The new case

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schedule shall be as follows:

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/
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Smith v. Harrington, et al.,/Case #C12-3533 LB (MEJ)
Stipulation And [Proposed] Order Extending Case Schedule

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EVENT

DEADLINE

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Fact deposition cutoff

June 20, 2014

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Designation of Opening Experts

June 27, 2014

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Designation of Rebuttal Experts

July 11, 2014

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Expert Discovery Cutoff

July 25, 2014

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Deadline(s) for Filing Discovery Motions

See Civil Local Rule 37-3

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Last hearing date for dispositive motions
and/or further case management conference

September 12, 2014, at 9:30 a.m.

Meet and confer re pretrial filings

November 13, 2014

October 17, 2014

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Pretrial filings

December 4, 2014

October 31, 2014

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Oppositions, Objections, Exhibits and
Deposition Designations due
December

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18, 2014

November 7, 2014

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Final Pretrial Conference

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Trial

January 29, 2015 at 1:30 p.m. November
February 17, 2015 at 8:30 a.m.
December

13, 2014, at 11:00 a.m.
15, 2014, at 8:30 a.m.

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Dated:

April 21, 2014

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U.S. Magistrate Judge Laurel Beeler
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Smith v. Harrington, et al.,/Case #C12-3533 LB (MEJ)
Stipulation And [Proposed] Order Extending Case Schedule