A.C. v. City of Santa Clara et al

Filing 62

ORDER by Judge Haywood S. Gilliam, Jr. Granting 61 Stipulation EXTENDING DEADLINES FOR FACT DISCOVERY, EXPERT DISCLOSURE/DISCOVERYAND DISPOSITIVE MOTIONS. (ndr, COURT STAFF) (Filed on 2/23/2015)

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Rebecca S. Widen, SBN 219207
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
CITY OF SANTA CLARA, MIKE HORN,
NATHAN CRESCINI, JOSH HIGGINS,
FRANK HAGG, and TROY CARDIN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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A. C., a minor, by and through his Guardian
Ad Litem, MARK CALHOUN,

)
)
)
Plaintiff,
)
)
vs.
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CITY OF SANTA CLARA, a municipal
)
corporation; MIKE HORN, individually and in )
his official capacities as a police officer for the )
CITY OF SANTA CLARA Police Department; )
NATHAN CRESCINI, individually and in his )
official capacities as a police officer for the
)
CITY OF SANTA CLARA Police Department; )
JOSH HIGGINS, individually and in his official )
capacities as a police officer for the CITY OF )
SANTA CLARA Police Department; FRANK )
HAGG, individually and in his official capacities )
as a police officer for the CITY OF SANTA
)
CLARA Police Department; TROY CARDIN; )
individually and in his official capacities as a
)
police officer for the CITY OF SANTA CLARA )
Police Department; and DOES 1-50, inclusive,, )
)
Defendant.
)
)

Case No.: C13-3276 HSG (NC)
STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINES FOR
FACT DISCOVERY, EXPERT
DISCLOSURE/DISCOVERYAND
DISPOSITIVE MOTIONS

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The parties hereto, by and through their respective counsel, hereby stipulate and request

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that the current deadlines for fact discovery, expert disclosure and discovery, and dispositive

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motions be extended by approximately 30 days, as set forth below. The current trial date would

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not be affected by the requested extension.

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The reason for the requested extension is that the parties require additional time to
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A. C., a minor, v. City of Santa Clara, et al.,/Case #C13-3276 HSG (NC)
Stipulation And [Proposed] Order Extending Deadlines For Fact Discovery, Expert Disclosure/Discovery And
Dispositive Motions

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conduct discovery. In particular, one of the defendant police officers is unable to sit for

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deposition due to a serious injury he sustained in a car accident. It is anticipated that the officer

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will be able to sit for deposition by mid-March. In addition, the parties require additional time

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to complete other necessary party and witness depositions. The parties expect to have these

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depositions completed by the end of March or early April. The undersigned attorneys are

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working diligently to get these depositions scheduled in a coordinated and timely manner.

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This is the first extension of the case schedule requested by the parties in this case. The
parties have agreed upon, and request the Court to adopt, the following new case schedule:
TRIAL DATE:

9/8/2015, at 8:30 a.m. (same as orig. date)

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FINAL PRETRIAL CONFERENCE:

8/11/2015, at 3:00 p.m.

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DISPOSITIVE MOTIONS:

Last day to be heard 7/2/2015, at 2:00 p.m.
See Civil Local Rules for notice and filing
requirements.

NON-EXPERT DISCOVERY CUT-OFF:

4/7/2015

EXPERT REPORTS:

Opening reports by 4/14/2015
Rebuttal reports by 5/5/2015

EXPERT DISCOVERY CUT-OFF:

5/22/2015

Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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IT IS SO STIPULATED.

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Dated: February 19, 2015

LAW OFFICES OF JOHN L. BURRIS

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By:
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*/s/ DeWitt M. Lacy
DeWitt M. Lacy
Attorneys for Plaintiffs
*Mr. Lacy provided his consent that this
document be electronically filed

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Dated: February 19, 2015

HAAPALA, THOMPSON & ABERN, LLP

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By:
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/s/ Rebecca S. Widen
Rebecca S. Widen
Attorneys for Defendants

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A. C., a minor, v. City of Santa Clara, et al.,/Case #C13-3276 HSG (NC)
Stipulation And [Proposed] Order Extending Deadlines For Fact Discovery, Expert Disclosure/Discovery And
Dispositive Motions

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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 as requested. The new case

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schedule shall be as follows:

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TRIAL DATE:

9/8/2015, at 8:30 a.m. (same as orig. date)

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FINAL PRETRIAL CONFERENCE:

8/11/2015, at 3:00 p.m.

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DISPOSITIVE MOTIONS:

Last day to be heard 7/2/2015 at 2:00 p.m.
See Civil Local Rules for notice and filing
requirements.

NON-EXPERT DISCOVERY CUT-OFF:

4/7/2015

EXPERT REPORTS:

Opening reports by 4/14/2015
Rebuttal reports by 5/5/2015

EXPERT DISCOVERY CUT-OFF:

5/22/2015

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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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Dated: 2/23/2015

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Hon. Haywood S. Gilliam, Jr.
United States District Judge

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A. C., a minor, v. City of Santa Clara, et al.,/Case #C13-3276 HSG (NC)
Stipulation And [Proposed] Order Extending Deadlines For Fact Discovery, Expert Disclosure/Discovery And
Dispositive Motions