Bhatnagar v. United States of America

Filing 75

ORDER GRANTING 73 STIPULATION EXTENDING DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES. Discovery due by 6/24/2016Dispositive Motions due by 7/22/2016Dispositive Motion Hearing set for 9/1/2016 Signed by Judge Maria-Elena James on 1/20/2016. (cdnS, COURT STAFF) (Filed on 1/20/2016)

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1 2 3 Stephanie P. Skaff (SBN 183119) sskaff@fbm.com Alex Reese (SBN 280530) areese@fbm.com Julia F. Kropp (SBN 298363) jkropp@fbm.com 4 5 6 FARELLA BRAUN + MARTEL LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 Telephone: (415) 954-4400 Facsimile: (415) 954-4480 7 8 Attorneys for Plaintiff Sanjay Bhatnagar Brian J. Stretch (SBN 163973) Acting United States Attorney Alex G. Tse (SBN 152348) Chief, Civil Division Robin M. Wall (SBN 235690) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-7071 Fax: (415) 436-6748 Robin.Wall@usdoj.gov Attorneys for Defendant United States of America 9 10 11 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA 14 15 Sanjay Bhatnagar, 16 17 18 19 Case No. 14-cv-00327-MEJ Plaintiff, vs. STIPULATION AND (PROPOSED) ORDER EXTENDING DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES The United States of America, Defendant. 20 21 22 23 24 25 26 27 28 Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 (415) 954-4400 Stipulation re Discovery and Dispos. Motion Deadlines / Case No. 14-cv-00327-MEJ 31195\5242168.1 1 Whereas, on December 15, 2015, after consulting with counsel for both parties, 2 Magistrate Judge Beeler continued the date for the settlement conference in this action to April 3 26, 2016 (Dkt. 70); 4 5 Whereas, the new settlement conference date falls just before the deadline for disclosure of expert witnesses, currently set for April 29, 2016 (Dkt. 65); 6 Whereas, in compliance with Judge Beeler’s order, counsel for the parties have met and 7 conferred regarding a plan for discovery to occur before the settlement conference, as described 8 in the declaration of Alex Reese filed with this stipulation in compliance with Civil L.R. 6-2; 9 Whereas, the parties have agreed that extending certain discovery and dispositive motion 10 deadlines would better facilitate discovery and allow for meaningful settlement discussion at the 11 April 26 conference; 12 13 14 15 Whereas, extending the discovery and dispositive motion deadlines would not impact the December 12, 2016 trial date or any pretrial deadlines in this case; Therefore, the parties hereby stipulate and agree that the following deadlines are extended as follows: 16 • Disclosure of Expert Witnesses: Extended from April 29, 2016 to May 27, 2016; 17 • Disclosure of Rebuttal Expert Witnesses: Extended from May 9, 2016 to June 10, 18 2016; 19 • Close of Discovery: Extended from May 24, 2016 to June 24, 2016; 20 • Deadline to File Dispositive Motions: Extended from June 23, 2016 to July 22, 21 22 2016; • Hearing on Dispositive Motions: Extended from July 28, 2016 at 10:00 a.m. to 23 September 1, 2016 at 10:00 a.m. (or any other date that is convenient for the 24 Court); 25 • All other dates remain unchanged. 26 27 28 Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 (415) 954-4400 Stipulation re Discovery and Dispos. Motion Deadlines / Case No. 14-cv-00327-MEJ -1- 31195\5242168.1 1 January 20, 2016 FARELLA BRAUN + MARTEL LLP 2 3 By: /s/ Alex Reese Alex Reese 4 Attorneys for Plaintiff Sanjay Bhatnagar 5 6 7 January 20, 2016 BRIAN J. STRETCH Acting United States Attorney 8 9 By: /s/ Robin M. Wall Robin M. Wall Assistant United States Attorney 10 11 Attorneys for Defendant United States of America 12 13 14 FILER’S ATTESTATION 15 In compliance with Civil L.R. Rule 5-1, I hereby attest that all parties have concurred in 16 the filing of this Stipulation and (Proposed) Order Extending Discovery and Dispositive Motion 17 Deadlines. 18 19 20 January 20, 2016 /s/ Alex Reese 21 Alex Reese 22 23 24 (PROPOSED) ORDER 25 26 27 In accordance with a stipulation between the parties, IT IS ORDERED that the deadlines for discovery and dispositive motions are hereby extended as follows: 28 Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 (415) 954-4400 Stipulation re Discovery and Dispos. Motion Deadlines / Case No. 14-cv-00327-MEJ -2- 31195\5242168.1 1 • Disclosure of Expert Witnesses: Extended from April 29, 2016 to May 27, 2016; 2 • Disclosure of Rebuttal Expert Witnesses: Extended from May 9, 2016 to June 10, 3 2016; 4 • Close of Discovery: Extended from May 24, 2016 to June 24, 2016; 5 • Deadline to File Dispositive Motions: Extended from June 23, 2016 to July 22, 6 7 2016; • Hearing on Dispositive Motions: Extended from July 28, 2016 at 10:00 a.m. to 8 September 1, 2016 at 10:00 a.m. (or any other date that is convenient for the 9 Court); 10 • All other dates remain unchanged. 11 12 13 January 20 Date: _____________, 2015 14 Honorable Maria-Elena James United States Magistrate Judge 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Farella Braun + Martel LLP 235 Montgomery Street, 17th Floor San Francisco, CA 94104 (415) 954-4400 Stipulation re Discovery and Dispos. Motion Deadlines / Case No. 14-cv-00327-MEJ -3- 31195\5242168.1

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