Chaitin-Lefcourt v. City and County of San Francisco

Filing 73

STIPULATION AND ORDER RE 72 TO AMEND INITIAL CASE MANAGEMENT SCHEDULING ORDER. Case Management Statement due by 7/14/2022. Further Case Management Conference set for 7/21/2022 at 10:00 AM in San Francisco, - Videoconference Only. Jury Selecti on/Trial set for 1/3/2023 09:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Pretrial Conference set for 12/21/2022 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Chief Judge Richard Seeborg on 1/7/2022. (cl, COURT STAFF) (Filed on 1/7/2022)

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Jianlin Song (SBN 289226)
[e-mail]
Peter Catalanotti (SBN 230743)
[e-mail]
Jenny Chien (SBN 327918)
[e-mail]
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
525 Market Street, 17th Floor
San Francisco, California 94105
Telephone: [phone]
Facsimile:
[phone]

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Attorneys for Cross-Defendant
HEALTHRIGHT 360 (erroneously sued as HEALTHRIGHT 360, INC.)

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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ADAM CHAITIN-LEFCOURT,

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Case No. 3:20-cv-05822-RS

Plaintiff,

JOINT STIPULATION TO AMEND
INITIAL CASE MANAGEMENT
SCHEDULING ORDER AND
ORDER

vs.
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CITY AND COUNTY OF SAN
FRANCISCO, a political subdivision of the
State of California, SAN FRANCISCO
POLICE DEPARTMENT; SFPD OFC
CHRISTOPHER M. DUNNE #1775; SFPD
OFC NASER #4289; SFPD OFC CHEW
#2088; SFPD OFC TOM #621; SFPD OFC
CHAVARIN #77; ANOTHER PLANET
ENTERTAINMENT, LLC; ADMIRAL
SECURITY SERVICES, INC.; ASHLEY
SAJLIAGA SALMIA; and DOES I through X,
inclusive,

Complaint filed: August 18, 2020
Judge: Hon. Richard Seeborg

Defendants.

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ANOTHER PLANET ENTERTAINMENT,
LLC,
Cross-complainant,
vs.
IPS SECURITY, INC.; HEALTHRIGHT 360,
INC. and DOES 1 to 50, inclusive,

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Cross-defendants.
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JOINT STIPULATION TO AMEND INITIAL CASE MANAGEMENT SCHEDULING ORDER AND [PROPOSED] ORDER
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On August 19, 2021, this Court issued an Initial Case Management Scheduling Order setting

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this case for trial (Docket No. 66). The Court set trial to commence on October 3, 2022 at 9:00

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a.m., and a final pretrial conference on September 21, 2022 at 10:00 a.m. The Court also set all

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corresponding pretrial deadlines.

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On November 23, 2021, Cross-Defendant HealthRight 360 (“HR 360”) and Cross-

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Complainant Another Planet Entertainment, LLC (“Another Planet”) filed a Stipulation to Set Aside

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Default Judgment and to Deem HR 360’s Answer to Cross-Complaint Filed. (Docket No. 70) On

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November 24, 2021, the Court granted the said Stipulation and vacated default judgment against

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HR 360. (Docket No. 71)

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As HR 360 has just joined this action, all parties in this action have stipulated to amend the

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Court’s Initial Case Management Scheduling Order to extend the trial date, pretrial conference date,

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and all pretrial deadlines by a period of 90 days.

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IT IS HEREBY STIPULATED, by and among all parties in this action, through their

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respective counsel of record, that the trial dates and pretrial deadlines be continued as follows:

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1. The parties agree that fact discovery cutoff date is extended to July 15, 2022;

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2. The parties agree that expert designation deadline is extended to August 15, 2022;

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3. The parties agree that supplemental and rebuttal expert designation deadline is extended

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to September 12, 2022;

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4. The parties agree that expert discover cutoff date is extended to October 3, 2022;

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5. The parties agree that a further Case Management Conference is extended to July 21,

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2022 at 10:00 a.m., or on any later date at the Court’s convenience;
6. The parties agree that dispositive pretrial motions, including motion for summary
judgment, shall be heard no later than October 27, 2022;
7. The parties agree that the final pretrial conference shall be held on December 21, 2022 at
10:00 a.m., or on any later date at the Court’s convenience;
8. The parties agree that a jury trial shall commence on January 3, 2023 at 9:00 a.m., or on
any later date at the Court’s convenience.

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JOINT STIPULATION TO AMEND INITIAL CASE MANAGEMENT SCHEDULING ORDER AND [PROPOSED] ORDER
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD SIGNED BELOW:

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Dated: January 7, 2022
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WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER
LLP

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By: /s/ Jianlin Song
Jianlin Song, Esq.
Peter Catalanotti, Esq.
Jenny Chien, Esq.
Attorneys for Cross-Defendant
HEALTHRIGHT 360, INC
E-signature authorized on Jan 7, 2022

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Dated: January 7, 2022

KERN SEGAL & MURRAY

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By: /s/ Phillip Segal
Phillip Segal Esq.
Attorney for Plaintiff
Adam Chaitin-Lefcourt
E-signature authorized on Jan 7, 2022

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Dated: January 6, 2022

MICHEL & FACKLER

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By:
Michael D. Michel, Esq.
Jeffrey D. Kirk, Esq.
Attorneys for Cross-complainant
ANOTHER PLANET ENTERTAINMENT

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Dated: January 7, 2022

OFFICE OF THE CITY ATTORNEY

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By: /s/ Ryan Stevens
Ryan Stevens, Esq.
Attorney for Defendant and Cross-Complainant
City and County of San Francisco
E-signature authorized on Jan 7, 2022

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JOINT STIPULATION TO AMEND INITIAL CASE MANAGEMENT SCHEDULING ORDER AND [PROPOSED] ORDER
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Dated: January 7, 2022

KASEM, KO & AHMED

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By: /s/ Ahmed Kasem
Ahmed Kasem
Attorney for Defendant
Admiral Security Inc.
E-signature authorized on Jan 7, 2022

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ORDER
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The Court, having considered the STIPULATION and having found GOOD CAUSE
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APPEARING,
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IT IS HEREBY ORDERED THAT:
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The Initial Case Management Scheduling Order is amended and the trial date and all pretrial
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deadlines set forth therein are extended as the parties have stipulated.
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Dated: January ___, 2022

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By:
Honorable Richard Seeborg
Chief United States District Judge

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JOINT STIPULATION TO AMEND INITIAL CASE MANAGEMENT SCHEDULING ORDER AND [PROPOSED] ORDER
265022488v.1