Winston et al v. Department of Agriculture et al

Filing 67

ORDER by Magistrate Judge Maria-Elena James granting 65 Stipulation. (rmm2S, COURT STAFF) (Filed on 7/14/2016)

1 BRIAN J. STRETCH (CABN 163973)
United States Attorney
2 SARA WINSLOW (DCBN 457643)
Chief, Civil Division
3 JENNIFER S WANG (CABN 233155)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
FAX: [phone]
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[e-mail]
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Attorneys for Federal Defendant
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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LUCILLE WINSTON and L.N.,
Plaintiffs,

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v.
UNITED STATES OF AMERICA, et al.,
Defendants.

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Case No. 14-cv-05417 MEJ (SK)
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DISCOVERY
AND DISPOSITIVE MOTIONS
DEADLINES

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Subject to the approval of the Court, plaintiffs Lucille Winston and L.N., 1 federal defendant

20 United States of America, and defendants Keenan Lee Grawe and Karen Himes Grawe, (collectively,
21 “the parties”) by and through their respective counsel, hereby stipulate to extend the deadlines for fact
22 and expert discovery, and the deadlines for dispositive motions. The parties, by and through their
23 counsel of record, hereby stipulate and agree as follows:
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1. Pursuant to the Court’s February 11, 2016 Case Management Order, the discovery and

25 dispositive motions deadlines are currently as follows:
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Disclosure of Expert Witnesses: August 12, 2016

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Pursuant to Federal Rule of Civil Procedure 5.2(a), only plaintiff’s initials are provided.

STIPULATION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES
CASE NO. 14-CV-05417 MEJ (SK)
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Disclosure of Rebuttal Expert Witnesses: August 22, 2016

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Close of Discovery: September 6, 2016

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Deadline to File Dispositive Motions: October 6, 2016
The initial pretrial conference is set for February 16, 2017; the final pretrial conference is set for

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5 March 16, 2017; and the trial in this case is set to begin on March 27, 2017.
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2.

The parties seek to extend the deadline for expert witnesses to September 19, 2016, the deadline

7 for disclosure of rebuttal expert witnesses to October 17, 2016, the close of discovery to November 18,
8 2016, and the deadline to file dispositive motions to October 27, 2016. The extension is needed because
9 the parties are currently in the process of scheduling mutually convenient dates for the depositions of the
10 plaintiffs in this action, and the parties anticipate that additional time after those depositions will be
11 needed to allow time for further fact and expert discovery.
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3. For the reasons discussed above, subject to the Court’s approval, the parties, through their

13 undersigned counsel, hereby agree and stipulate to extend the expert disclosure deadline from August
14 12, 2016 to September 19, 2016; the rebuttal expert disclosure deadline from August 22, 2016 to
15 October 17, 2016; the close of expert discovery from September 6, 2016 to November 18, 2016; and the
16 deadline to file dispositive motions from October 6, 2016 to October 27, 2016. All other case
17 management dates, including the trial date, would remain the same.
18 IT IS SO STIPULATED.
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21 Dated: July 13, 2016
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23 Dated: July 13, 2016
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Respectfully submitted,
BRIAN J. STRETCH
United States Attorney
/s/ Jennifer S Wang
JENNIFER S WANG*
Assistant United States Attorney
LAW OFFICES OF BRIAN L. LARSEN
/s/ Brian L. Larsen
BRIAN L. LARSEN
Attorneys for Plaintiffs

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Dated: July 11, 2016
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VOGL MEREDITH & BURKE LLP
/s/ Michael Burke
MICHAEL BURKE
Attorneys for Defendants Keenan Lee
Grawe and Karen Himes Grawe

STIPULATION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES
CASE NO. 14-CV-05417 MEJ (SK)
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1 *In compliance with Civil Local Rule 5-1(i), the filer of this document attests that plaintiffs and
defendants Keenan and Karen Grawe have concurred in the filing of this document.
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[PROPOSED] ORDER

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Pursuant to the parties= stipulation and good cause having been shown, it is hereby ordered that:
1. The deadline for disclosure of expert witnesses is September 19, 2016
2. The deadline for disclosure of rebuttal expert witnesses is October 17, 2016
3. The close of discovery will be November 18, 2016
4. The deadline to file dispositive motions will be October 27, 2016, and the last day to hear
dispositive motions will be December 1, 2016.

10 IT IS SO ORDERED.
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July 14, 2016
Dated:________________

_______________________________
HON. MARIA-ELENA JAMES
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO EXTEND DISCOVERY AND DISPOSITIVE MOTIONS DEADLINES
CASE NO. 14-CV-05417 MEJ (SK)
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