Freeman v. United States

Filing 103

Order by Hon. Vince Chhabria granting 102 Stipulated Request for Order Changing Time. (Attachments: # 1 Certificate/Proof of Service)(knm, COURT STAFF) (Filed on 10/6/2014)

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MELINDA HAAG (CABN 132612) 1 United States Attorney ALEX G. TSE (CABN 152348) 2 Chief, Civil Division REBECCA A. FALK (CSBN 226798) 3 Assistant United States Attorney 4 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-7022 FAX: (415) 436-6748 rebecca.falk@usdoj.gov 5 6 7 Attorneys for Federal Defendant 8 Welborn Freeman 276 Lee Street, #101 9 Oakland, CA 94610 10 Plaintiff, Pro Se 11 UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 15 WELBORN FREEMAN, 16 17 18 19 20 Plaintiff, v. UNITED STATES OF AMERICA Defendant. ) CASE NO. 13-02421 VC ) ) ) JOINT STIPULATED REQUEST FOR ORDER ) CHANGING TIME AND [PROPOSED] ORDER ) ) ) ) ) 21 22 23 24 25 26 27 28 JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER 13-02421 VC 30 1 Defendant United States of America (“Defendant”), by and through its undersigned counsel and 2 Plaintiff Welborn Freeman, Pro Se (“Plaintiff”), hereby stipulate that the current case schedule should be 3 vacated pending assignment of a pro bono attorney to Plaintiff pursuant to Civil Local Rule 6-1(a) of the 4 Northern District of California, as follows: 5 1. On January 29, 2014, this Court entered a Case Management Schedule setting the 6 following dates. Dkt. No. 80. 7 Fact discovery cut off: October 31, 2014 8 Expert disclosure deadline: November 14, 2014 9 Rebuttal expert disclosure: December 19, 2014 10 Expert discovery cut-off: January 20, 2015 11 Dispositive Motion Hearing: March 19, 2015 12 Pretrial Conference: May 29, 2015 13 Trial Date: June 29, 2015 14 2. On July 29, 2014, this Court entered an Order Referring Plaintiff to the Federal Pro Bono 15 Project in response to his request for appointment of counsel, and further staying this matter until four 16 weeks from the date an attorney is appointed to represent Plaintiff. Dkt. No 98. 17 3. Given the approach of the close of fact discovery and the fact that an attorney has not yet 18 been appointed to Plaintiff, the parties hereby stipulate and respectfully request that the Court vacate the 19 current Case Management Schedule and reset all deadlines in this matter once counsel has been 20 appointed to Plaintiff. The parties respectfully suggest that the Court set a deadline for submission of a 21 Case Management Statement for a date after the appointment of counsel to allow for a suggested 22 schedule subject to the approval of the Court or to request a Case Management Conference if no such 23 schedule can be agreed upon. Because the stay in this matter is scheduled to be lifted automatically four 24 weeks from the date an attorney is appointed to represent Freeman in this action, the parties also 25 respectfully suggest that the Court order submission of the Case Management Statement 30 days after 26 the stay is automatically lifted. 27 IT IS SO STIPULATED. 28 /// JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER 13-02421 VC 30 October 6, 2014

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