Perez v. Prelip et al

Filing 65

STIPULATION AND ORDER re 64 Stipulation to Extend Expert Discovery Cut-off to March 13, 2015. Signed by Judge Vince Chhabria on 2/9/2015. (knm, COURT STAFF) (Filed on 2/9/2015)

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Randall R. Lee (SBN: 152672)
[e-mail]
Matthew D. Benedetto (SBN: 252379)
[e-mail]
Katie Moran (SBN: 272041)
[e-mail]
Wilmer Cutler Pickering Hale and Dorr LLP
350 South Grand Avenue, Suite 2100
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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Kamala D. Harris
Attorney General of California
William C. Kwong
Supervising Deputy Attorney General
Jennifer J. Nygaard (SBN: 229494)
[e-mail]
1515 Clay Street, 20th Floor
P.O. Box 70550
Oakland, CA 94612-0550
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants Burris, Gates
Gongora, Healy, Pimentel, and Prelip

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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JESSE PEREZ

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Case No. 3:13-cv-05359-VC
Plaintiff,

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vs.

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JOINT STIPULATION TO
EXTEND EXPERT DISCOVERY
CUT-OFF TO MARCH 13, 2015
PURSUANT TO L.R. 6-1(A)

J. PRELIP, et al.,

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Defendant.

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JOINT STIPULATION
Case No. 3:13-cv-05359-VC
ActiveUS 140801770v.3

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Under Civil Local Rule 6-1(a), Plaintiff Jesse Perez and Defendants Burris, Gates,

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Gongora, Healy, Pimentel, and Prelip (Defendants) stipulate to extend the time for the parties to

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complete expert discovery to March 13, 2015.

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The initial Case Management Conference in this action was held on August 28, 2014

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during which the Court set a fact discovery cut-off date of January 16, 2015, a dispositive motion

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filing deadline of March 19, 2015, and a trial date for June 8, 2015. The parties also agreed to a

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February 20, 2015 cut-off for expert discovery, though it was not entered in the Court’s order.

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(Docket No. 43). The parties completed fact discovery on January 16, 2015.

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A Further Case Management Conference was held on February 3, 2015. At that

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conference, at the request of Plaintiff, the Court continued the trial date to July 27, 2015.

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(Docket No. 62). At Defendants’ request, the Court also permitted an extension of the

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dispositive motion deadline, setting May 21, 2015 as the last day for a hearing on such a motion.

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The parties have conferred and hereby agree to extend the deadline for expert discovery

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to March 13, 2015, which is in accordance with, and does not alter, the rest of the scheduling

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dates.

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IT IS STIPULATED AND AGREED that the time for the parties to complete expert
discovery is extended up to and including March 13, 2015.

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-1JOINT STIPULATION
Case No. 3:13-cv-05359-VC
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Dated: February 6, 2015

WILMER CUTLER PICKERING
HALE AND DORR LLP

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By:
/s/ Matthew D. Benedetto
Randall R. Lee
Matthew D. Benedetto
Katie Moran
350 South Grand Avenue, Suite 2100
Los Angeles, CA 90071

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Attorneys for Plaintiff Jesse Perez

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Dated: February 6, 2015

KAMALA D. HARRIS
Attorney General of California

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By:
/s/ Jennifer J. Nygaard
Jennifer J. Nygaard
CA State Attorney General’s Office
1515 Clay Street, 20th Floor
P. O. Box 70550
Oakland, CA 94612-0550

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Attorneys for Defendants Burris, Gates,
Gongora, Healy, Pimentel, and Prelip

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UNIT
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Date: February 9, 2015

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-2JOINT STIPULATION
Case No. 3:13-cv-05359-VC
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