Arambula v. Kimber et al

Filing 24

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER FOR EXTENSION OF TIME TO COMPLETE SETTLEMENT CONFERENCE AND AMENDED SCHEDULING ORDER filed by Alberto N. Arambula. Signed by Judge Jon S. Tigar on September 11, 2014. (wsn, COURT STAFF) (Filed on 9/11/2014)

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1 2 3 4 5 6 7 8 9 10 11 12 JOHN L. BURRIS, ESQ. SB#69888 BENJAMIN NISEBAUM, ESQ. SB: 222173 LAW OFFICES OF JOHN L. BURRIS Airport Corporate Centre 7677 Oakport Street, Suite 1120 Oakland, CA 94621-1939 Tel: (510) 839-5200 Fax: (510) 839-3882 E/M: john.burris@johnburrislaw.com Attorneys for Alberto Arambula RICHARD DOYLE, City Attorney (88625) NORA FRIMANN, Assistant City Attorney (93249) RANDOLPH S. HOM, Senior Deputy City Attorney (152833) Office of the City Attorney 200 East Santa Clara Street, 16th Floor San José, California 95113-1905 Telephone Number: (408) 535-1900 Facsimile Number: (408) 998-3131 E-Mail Address: cao.main@sanjoseca.gov 13 14 Attorneys for Defendants RYAN KIMBER and MATTHEW HAYWARD 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 18 ALBERTO ARAMBULA, an individual, 19 20 Plaintiff, vs. 21 25 RYAN KIMBER, an individual; MATTHEW HAYWARD, an individual and DOES 1-50, inclusive; individually and in their capacities as law enforcement agents and/or personnel for the SAN JOSE POLICE DEPARTMENT, 26 Case: 13-cv-05697-JST STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO COMPLETE SETTLEMENT CONFERENCE AND AMENDED SCHEDULING ORDER Defendants. 22 23 24 27 28 1 STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO COMPLETE SETTLEMENT CONFERENCE AND AMENDED SCHEDULING ORDER 1 STIPULATION 2 3 4 All parties to this action stipulate and agree, by and through their respective counsel, as follows: 5 6 1. On May 14, 2014, the parties in this matter appeared before the Court during an initial 7 Case Management Conference. The parties were referred to Magistrate Judge Beeler 8 for a settlement conference to be completed by August 15, 2014; 9 2. On May 19, 2014, Judge Beeler notified the parties that a Settlement Conference was 10 11 12 scheduled for September 16, 2014; 3. Presently, Plaintiff’s counsel Benjamin Nisenbaum and John L. Burris are unavailable 13 for Settlement Conference currently scheduled for September 16, 2014 due to 14 scheduling conflicts. Plaintiff’s counsel are currently engaged in Trial before the 15 Honorable Jeffrey S. White in the matter or Espinosa, et al. v. City and County of San 16 17 Francisco, et al. 4:06-cv-04686 JSW. The Trial is expected to last six (6) weeks; 18 4. In anticipation of the Settlement Conference, to keep attorney fees at a minimum, the 19 parties have not yet served written discovery on each other, which will, of course, not 20 be responded to until at least 33 days after service. Also, counsel have not yet 21 conducted any depositions in this case; and, 22 23 5. Therefore, the parties request that this Court extend the time for completion of 24 Settlement Conference from the presently scheduled date for completion, 08-15-14, to 25 a date ninety (90) days from that date; the parties similarly request that the Court adjust 26 the dates in its Scheduling Order dated June 3, 2014 such that all dates for completion 27 28 2 STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO COMPLETE SETTLEMENT CONFERENCE AND AMENDED SCHEDULING ORDER 1 are extended by ninety (90) days including but not limited to dates relating to fact 2 3 discovery, expert disclosure and discovery, dispositive motions, and jury trial. 4 5 Respectfully submitted, 6 LAW OFFICES OF JOHN L. BURRIS 7 Dated: September 8, 2014 8 9 /s/ Benjamin Nisenbaum John L. Burris, Esq. Benjamin Nisenbaum, Esq. Attorneys for Plaintiff Alberto Arambula 10 11 RICHARD DOYLE, City Attorney 12 13 Dated: September 9, 2014 14 15 /s/ Randolph S. Hom RANDOLPH S. HOM, Senior Deputy City Attorney Attorneys for Defendants RYAN KIMBER and MATTHEW HAYWARD 16 17 18 19 (PROPOSED) ORDER 20 PURSUANT TO STIPULATION, IT IS SO ORDERED. S DISTRICT TE C A FO RT 28 NO 27 Dated: September 11, 2014 LI 26 D RDERE S SO O IT I _____________________________ HONORABLE JON S. TIGAR ar UNITED STATES DISTRICTgCOURT n S . Ti J u d ge J o R NIA 25 T RT U O 24 H E A 23 S 22 ORDER UNIT ED 21 RN STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO F C COMPLETE D IS SETTLEMENT CONFERENCE AND AMENDED SCHEDULING ORDERO CT TRI 3

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