Novoa v. City and County of San Francisco et al

Filing 21

STIPULATION AND ORDER re 20 STIPULATION WITH PROPOSED ORDER REGARDING DISCOVERY DEADLINES filed by Debra Franks, City and County of San Francisco. Signed by Judge Jon S. Tigar on May 16, 2015. (wsn, COURT STAFF) (Filed on 5/26/2015)

1
2
3
4
5
6

DENNIS J. HERRERA, State Bar #139669
City Attorney
ELIZABETH SALVESON, State Bar #83788
Chief Labor Attorney
BORIS REZNIKOV, State Bar #261776
Deputy City Attorney
Fox Plaza
1390 Market Street, Fifth Floor
San Francisco, California 94102-5408
Telephone:
(415) 554- 3868
Facsimile:
[phone]
E-Mail:
[e-mail]

7
8
9
10
11
12
13
14
15

Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO
and DEBORAH FRANKS
Russell A. Robinson, State Bar #163937
Law Office of Russell A. Robinson
345 Grove St, First Floor
San Francisco, CA 94102
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorney for Plaintiff
GREGORY NOVOA

16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18
19

GREGORY NOVOA,

20

Plaintiff,

21

vs.

22
23
24

CITY AND COUNTY OF SAN
FRANCISCO, SAN FRANCISCO
MUNICIPAL TRANSIT AGENCY, DEBRA
FRANKS, MIKE HELMS, and DOES 1-40,

Case No. C 14-03617-JST
JOINT STIPULATION REGARDING
DISCOVERY DEADLINES UNDER CIVIL
LOCAL RULE 6-2(A); [PROPOSED] ORDER
Judge:
Court:

Honorable Jon S. Tigar
450 Golden Gate, Courtroom 9 (Floor 19)

File Date: June 13, 2013
Trial Date: January 11, 2016

Defendants.

25
26
27
28

Joint Stipulation Regarding Discovery
Deadlines; [Proposed] Order
Case No. 14-03617-JST

1

c:\users\brezniko\desktop\pldg stipulation re scheduling.doc

Pursuant to Civil Local Rule 6-2(a), Plaintiff Gregory Novoa and Defendants City and County

1
2

of San Francisco and Deborah Franks hereby submit the following stipulation and proposed order

3

regarding Defendants’ motion to compel deadline.
1.

4
5

On November 17, 2014, the Court issued the following deadlines as part of its case

management schedule:

6

Fact Discovery Cut-Off:

May 18, 2015

7

Deadline to File Dispositive Motions:

July 2, 2015

8

Trial Date:

January 11, 2016

9

(Dkt. No. 19.) Through this stipulation, the parties are jointly requesting an extension permitting

10

Defendants to file a motion to compel regarding their document requests after the dispositive motion

11

hearing in this matter, if such a motion to compel is needed. This is the parties’ first request to modify

12

any deadlines in this case.
2.

13

Defendants served document requests on Plaintiff on April 17. Plaintiff was required to

14

respond by May 18, but no responses were provided. Defendants are willing to move for summary

15

judgment without raising this discovery dispute to the Court at this time, but only if Defendants are

16

permitted to file a motion to compel — if needed — after the Court rules on their motion for summary

17

judgment. The parties therefore jointly request that Defendants’ motion to compel deadline under

18

Civil Local Rule 37-3, with respect to only the document requests served on April 17, be extended

19

until 30 days after the Court rules on Defendants’ summary judgment motion. Such an extension will

20

not affect any other deadlines in this case or the trial date, which is not until January 11, 2016.

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

Joint Stipulation Regarding Discovery
Deadlines; [Proposed] Order
Case No. 14-03617-JST

2

c:\users\brezniko\desktop\pldg stipulation re scheduling.doc

1

Dated: May 20, 2015

2
3

DENNIS J. HERRERA
City Attorney
ELIZABETH S. SALVESON
Chief Labor Attorney
BORIS REZNIKOV
Deputy City Attorney(s)

4
By:/s/ Boris Reznikov
BORIS REZNIKOV
Attorneys for Defendant(s)
CITY AND COUNTY OF SAN FRANCISCO

5
6
7
8
9

Dated: May 20, 2015

RUSSELL A. ROBINSON
Law Office of Russell A. Robinson

10
By: /s/ Russell A. Robinson
RUSSELL A. ROBINSON
Attorney for Plaintiff
GREGORY NOVOA

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Joint Stipulation Regarding Discovery
Deadlines; [Proposed] Order
Case No. 14-03617-JST

3

c:\users\brezniko\desktop\pldg stipulation re scheduling.doc

[PROPOSED] ORDER

1
2
3
4

Pursuant to Plaintiff Gregory Novoa’s and Defendants City and County of San Francisco and
Deborah Franks’ stipulation, it is hereby ordered as follows:
Defendants’ motion to compel deadline for the document requests they propounded on Plaintiff

5

on April 17, 2015 is extended until 30 days after the Court rules on Defendants’ summary judgment

6

motion.

S

10

NO
RT

ER

. Ti ga r

13
14

A

H

12

nS
J u d ge J o

LI

11

R NIA

9

_____________________________________
The Honorable Jon RDERED
S. Tigar
IS SO O Judge
United States District
IT

FO

26
Dated: May ___, 2015

UNIT
ED

8

RT
U
O

7

S DISTRICT
TE
C
TA

N

D IS T IC T
R

OF

C

15
16
17
18
19
20
21
22
23
24
25
26
27
28

Joint Stipulation Regarding Discovery
Deadlines; [Proposed] Order
Case No. 14-03617-JST

4

c:\users\brezniko\desktop\pldg stipulation re scheduling.doc