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)
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?