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

Filing 86

ORDER by Judge Haywood S. Gilliam, Jr. Granting 85 Stipulation EXTENDING EXPERT DISCLOSURE AND DISCOVERY DEADLINES. (ndr, COURT STAFF) (Filed on 6/17/2015)

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

Case No.: C13-3276 HSG (NC)
STIPULATION AND [PROPOSED]
ORDER EXTENDING REBUTTAL
EXPERT DISCLOSURE AND
DISCOVERY DEADLINES

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

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that the rebuttal expert disclosure and discovery deadlines be extended by approximately two

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weeks, as set forth below. The remainder of the case schedule, including the trial date, is not

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affected by the requested extension.

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The reason for the requested extension is that Defendants anticipate that their rebuttal
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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 Rebuttal Expert Disclosure And Discovery Deadlines

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expert(s) will rely, in part, on the report of defense neuropsychologist Dr. Ruff in order to form

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their opinions in this matter. The deadline for disclosure of Dr. Ruff’s opening report was

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recently extended to June 26, 2015, due to Plaintiff’s failure to attend his originally-scheduled

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Rule 35 examination with Dr. Ruff (Docket #75). The parties now request that the rebuttal

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expert report and discovery deadlines be extended accordingly.

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This is the fifth extension of the case schedule requested by the parties in this case. The

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parties have agreed upon, and request the Court to adopt, the following new case schedule. All

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previous dates remain unchanged; the only changes are the new deadlines applying to rebuttal

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expert disclosure and discovery.

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

TRIAL DATE:

9/8/2015, at 8:30 a.m.

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Haapala, Thompson & Abern LLP

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FINAL PRETRIAL CONFERENCE:

8/11/2015, at 2:30 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

OPENING EXPERT REPORTS:

6/5/15

DR. RUFF’S EXPERT REPORT:

6/25/2015

REBUTTAL EXPERT REPORTS:

7/3/15

OPENING EXPERT
DISCOVERY CUTOFF:

7/8/2015

REBUTTAL EXPERT AND DR.
RUFF DISCOVERY CUTOFF:

7/10/2015

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IT IS SO STIPULATED.

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Dated: June 16, 2015

LAW OFFICES OF JOHN L. BURRIS
By:

*/s/ DeWitt M. Lacy
DeWitt M. Lacy
Attorneys for Plaintiffs
*Mr. Lacy provided his consent that this

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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 Rebuttal Expert Disclosure And Discovery Deadlines

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document be electronically filed

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Dated: June 16, 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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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.

FINAL PRETRIAL CONFERENCE:

8/11/2015, at 2:30 p.m.

DISPOSITIVE MOTIONS:

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

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NON-EXPERT DISCOVERY CUT-OFF:

4/7/2015

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OPENING EXPERT REPORTS:

6/5/15

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DR. RUFF’S EXPERT REPORT:

6/25/2015

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REBUTTAL EXPERT REPORTS:

7/3/15

OPENING EXPERT
DISCOVERY CUTOFF:

7/8/2015

REBUTTAL EXPERT AND DR.
RUFF DISCOVERY CUTOFF:

7/10/2015

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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Dated: 6/17/2015

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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 Rebuttal Expert Disclosure And Discovery Deadlines