Rebucas et al v. City of San Bruno et al

Filing 77

STIPULATION AND ORDER re 76 CONTINUING EXPERT DISCOVERY DEADLINES to 3/31/2017. 3/9/2017 motion hearing vacated. Signed by Judge Edward M. Chen on 2/3/17. (bpfS, COURT STAFF) (Filed on 2/3/2017)

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JOHN L. BURRIS, Esq. (SBN 69888)
DeWITT M. LACY, Esq. (SBN 258789)
THE LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs
ANNE REBUCAS, et al

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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ANNE REBUCAS, et al,

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Case No.: 3:14-cv-03313-EMC

Plaintiff,

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STIPULATION AND [PROPOSED] ORDER
CONTINUING EXPERT DISCOVERY
DEADLINES

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vs.

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CITY OF SAN BRUNO, et al,

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Defendants.

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TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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WHEREAS, the parties are currently not in possession of the Total Station Laser Scan

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performed by and during the San Mateo County District Attorney’s investigation of the subject

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incident;

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WHEREAS, counsel for Defendants are attempting to secure said Total Station Laser Scan

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data from the San Mateo County District Attorney’s Office and have agreed to produce same to

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counsel for Plaintiffs if and when received;

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STIPULATION AND [PROPOSED] ORDER CONTINUING EXPERT DISCOVERY DEADLINES
USDC No. 3:14-cv-03313-EMC

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WHEREAS, in response to Plaintiffs’ request, Defendants have agreed to produce the

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underlying data obtained from laser scans performed by their designated experts, Ted Kobayashi and

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Craig Fries;
WHEREAS, Plaintiffs contend that the disclosure of this underlying data is necessary for

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Plaintiffs’ experts to accurately examine the evidence for the purpose of reconstruction and rebuttal,

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if necessary;
IT IS HEREBY STIPULATED by and between plaintiffs ANNE REBUCAS, et al, and

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Defendants CITY OF SAN BRUNO, et al, through their counsel of record, in the interests of judicial

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economy and justice, all would benefit from a continuance of the initial and rebuttal expert report

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deadlines, which are presently set for January 12, 2017 and February 2, 2017, respectively, (see

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Document No. 53 at 1:27-8) to March 1, 2017. The parties further agree that the expert discovery

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cut-off should and will be extended from February 23, 2017 (see Document 53 at 2:1) to March 31,

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2017.

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IT IS SO STIPULATED.

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Dated: February 2, 2017

THE LAW OFFICES OF JOHN L. BURRIS

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By __/s/ DeWitt Lacy______________
DeWITT M. LACY, Esq.
Attorney for Plaintiff

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Dated: February 2, 2017

HOWARD ROME MARTIN & RIDLEY LLP

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By */s/
Todd Holton Master
Shawn Michael Ridley
Attorneys for Defendants
CITY OF SAN BRUNO, ET AL
*Mr.Master has given his consent to file this
document electronically.
STIPULATION AND [PROPOSED] ORDER CONTINUING EXPERT DISCOVERY DEADLINES
USDC No. 3:14-cv-03313-EMC

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, the Court hereby modifies its Case Management and

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Pretrial Order for Jury Trial (Document No. 53) to extend the deadline for the production of initial

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and rebuttal expert reports to March 1, 2017 and to extend the expert discovery cut-off to March 31,

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2017. The March 9, 2017 motion hearing is vacated.

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ER

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Judge E

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IT IS S
DIFIED
AS MO

NO

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___________________________
D
HONORABLEERE
O ORD JUDGE CHEN
Chen

FO

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Dated: February _____, 2017

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S DISTRICT
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SO ORDERED.

UNIT
ED

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D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER CONTINUING EXPERT DISCOVERY DEADLINES
USDC No. 3:14-cv-03313-EMC

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