Kueberth v. City of Ukiah et al

Filing 58

STIPULATION AND ORDER re 57 STIPULATION WITH PROPOSED ORDER; Stipulated Request for Order Extension of Time to File Discovery Motions filed by Julian Covella, Kevin Murray, Chris Dewey, City of Ukiah. Signed by Judge Jon S. Tigar on May 21, 2014. (wsn, COURT STAFF) (Filed on 5/21/2014)

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STEVEN C. MITCHELL, ESQ., SBN 1124644
ROBERT W. HENKELS, ESQ., SBN 255410
GEARY, SHEA, O’DONNELL, GRATTAN & MITCHELL, P.C.
37 Old Courthouse Square, Fourth Floor
Santa Rosa, California 95404
Telephone: [phone]
Facsimile: 707/545-1876
Attorneys for Defendants
CITY OF UKIAH, POLICE CHIEF CHRIS DEWEY,
OFFICER JULIAN COVELLA and OFFICER KEVIN MURRAY
DEREK FORAN (CA SBN 224569)
[e-mail]
KAY FITZ-PATRICK (CA SBN 252977)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Plaintiff
NOELLE KUEBERTH

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT

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NOELLE KUEBERTH,

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Plaintiff,

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v.

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CITY OF UKIAH, POLICE CHIEF CHRIS
DEWEY, OFFICER JULIAN COVELLA,
OFFICER KEVIN MURRAY, DOES 1 to 10,
inclusive,

CASE NO.: CV 12-4272 JST
STIPULATED REQUEST FOR ORDER
EXTENSION OF TIME TO FILE
DISCOVERY MOTIONS [Civil L.R. 6-2(a)];
[Proposed] ORDER THEREON
Unlimited Civil

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Defendants.
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LAW OFFICES OF

GEARY,
SHEA,
O’DONNELL,
GRATTAN &

MITCHELL
P.C.

TO THIS HONORABLE COURT:

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The parties hereby request, by way of stipulation, an order extending the deadline to file

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motions to compel fact discovery from May 21, 2014 to June 4, 2014. In so doing, the parties, by

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and through their counsel of record, agree and stipulate as follows:
________________________________________________________________________________
-1Stipulated Request and Order for Extension of Time to File Discovery Motions 12-cv-04272-JST

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1.

The last day to file a motion to compel, per local rule, is May 21, 2014. The fact

discovery cut-off date per this Court’s Scheduling Order is May 14, 2014, and Civil Local Rule 373 sets the last day for discovery motions one week later.
2.

The parties wish to ensure sufficient time to meaningfully meet and confer should

any dispute regarding written discovery arise, and therefore stipulate that good cause exists to
change time. The parties thus request a two-week extension of time to file a motion to compel.
3.

The parties have not previously stipulated or agreed to any prior time modification,

although the Court did order a new trial schedule upon appointment of counsel for plaintiff.
4.

The instant extension of time would not otherwise significantly affect the schedule

of this case.
IT IS SO STIPULATED.

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DATED: May 13, 2014

GEARY, SHEA, O'DONNELL, GRATTAN &
MITCHELL, P.C.

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By
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DATED: May 13, 2014

/s/ Robert W. Henkels
ROBERT W. HENKELS
Attorneys for Defendants
CITY OF UKIAH, POLICE CHIEF CHRIS
DEWEY, OFFICER JULIAN COVELLA and
OFFICER KEVIN MURRAY

MORRISON & FOERSTER LLP

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By: /s/ Kay Fitz-Patrick
KAY FITZ-PATRICK
Attorneys for Plaintiff
NOELLE KUEBERTH

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ORDER

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LAW OFFICES OF

GEARY,
SHEA,
O’DONNELL,
GRATTAN &

MITCHELL
P.C.

After review of the parties’ Stipulation and Request, and good cause appearing, the Court

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hereby GRANTS the parties’ request to change time and EXTENDS the last day for the parties to

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file motions to compel fact discovery to currently outstanding discovery from May 21, 2014 to June

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4, 2014.
________________________________________________________________________________
-2Stipulated Request and Order for Extension of Time to File Discovery Motions 12-cv-04272-JST

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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S

ER

R NIA

S . Ti ga r

FO

n
J u d ge J o

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RT

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NO

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Honorable Jon S. Tigar
UNITED STATES DISTRICT COURT
DERED
JUDGES SO OR
IT I

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RT
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S DISTRICT
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TA
______________________________

Dated: May 21, 2014

UNIT
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D IS T IC T O
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LAW OFFICES OF

GEARY,
SHEA,
O’DONNELL,
GRATTAN &

MITCHELL
P.C.

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________________________________________________________________________________
-3Stipulated Request and Order for Extension of Time to File Discovery Motions 12-cv-04272-JST

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E-FILING ATTESTATION

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I, Robert Henkels, am the ECF User whose ID and password are being used to file the

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foregoing document. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Kay FitzPatrick has concurred in this filing.
By

/s/
ROBERT W. HENKELS

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LAW OFFICES OF

GEARY,
SHEA,
O’DONNELL,
GRATTAN &

MITCHELL
P.C.

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________________________________________________________________________________
-4Stipulated Request and Order for Extension of Time to File Discovery Motions 12-cv-04272-JST