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)
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
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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15
WELBORN FREEMAN,
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Plaintiff,
v.
UNITED STATES OF AMERICA
Defendant.
) CASE NO. 13-02421 VC
)
)
) JOINT STIPULATED REQUEST FOR ORDER
) CHANGING TIME AND [PROPOSED] ORDER
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JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
13-02421 VC
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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.
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Fact discovery cut off: October 31, 2014
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Expert disclosure deadline: November 14, 2014
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Rebuttal expert disclosure: December 19, 2014
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Expert discovery cut-off: January 20, 2015
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Dispositive Motion Hearing: March 19, 2015
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Pretrial Conference: May 29, 2015
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Trial Date: June 29, 2015
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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.
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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.
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IT IS SO STIPULATED.
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JOINT STIPULATED REQUEST FOR ORDER CHANGING TIME AND [PROPOSED] ORDER
13-02421 VC
30
October 6, 2014
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