Williams, et al v. City of Antioch, et al
Filing
218
STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Discovery due by 12/5/2011. Jury Trial set for 5/7/2012 08:30 AM before Hon. Saundra Brown Armstrong. Motions due by 2/14/2012. Pretrial Conference set for 4/24/2012 01:00 PM before Hon. Saundra Brown Armstrong.. Signed by Judge ARMSTRONG on 9/15/11. (lrc, COURT STAFF) (Filed on 9/19/2011)
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Impact Fund
BRAD SELIGMAN (SBN 083838)
bseligman@impactfund.org
JOCELYN D. LARKIN (SBN 110817)
125 University Avenue, Suite 102
Berkeley, CA 94710
Telephone: 510.845.3473
Facsimile: 510.845.3654
American Civil Liberties Union
Foundation of Northern California
ALAN L. SCHLOSSER (SBN 49957)
aschlosser@aclunc.org
39 Drumm Street
San Francisco, CA 94111
Telephone: 415.621.2493
Bingham McCutchen LLP
FRANK KENNAMER (SBN 157844)
Three Embarcadero Center
San Francisco, CA 94111-4067
Telephone: 415.393.2000
Public Advocates, Inc.
RICHARD A. MARCANTONIO (SBN
39619)
Rmarcantonio@publicadvocates.org
131 Steuart Street, Suite 300
San Francisco, CA 94105
Telephone: 415.431.7430
Lawyers’ Committee For Civil Rights of the San
Francisco Bay Area
OREN M. SELLSTROM (SBN 161074)
osellstrom@lccr.com
131 Steuart Street, Suite 400
San Francisco, CA 94105
Telephone: 415.543.9444
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Covington & Burling,
HAYWOOD GILLIAM, Jr. (SBN 172732)
hgilliam@covington.com
One Front St.
San Francisco, CA 94111
Telephone: 415.955-6530
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Attorneys for Plaintiffs
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Attorneys for Plaintiffs
McNamara, Dodge, Ney, Beatty, Slattery,
Pfalzer, Borges & Brothers LLP
JAMES V. FITZGERALD, III (SBN
55632)
THOMAS G. BEATTY (SBN 75794)
NOAH G. BLECHMAN (SBN 197167)
1211 Newell Avenue, P.O. Box 5288
Walnut Creek, CA 94596
Telephone: 925.939.5530
Facsimile: 925.939.0203
Attorneys for Defendant
CITY OF ANTIOCH
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SANTEYA DANYELL WILLIAMS,
MARY RUTH SCOTT, KAREN
LATREECE COLEMAN, PRISCILLA
BUNTON, and ALYCE DENISE PAYNE,
on behalf of themselves and all others
similarly situated,
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No. C-08-2301 SBA (EDL)
SUPPLEMENTAL JOINT REQUEST AND
ORDER TO MODIFY CASE DEADLINES
Plaintiffs,
v.
CITY OF ANTIOCH,
Defendant.
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NO.: C-08-2301 SBA (EDL)
A/72860666.1
JOINT REQUEST TO MODIFY CASE DEADLINES
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The Court recently denied the parties’ joint request to modify deadlines and referred the
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matter to Magistrate Judge Corley. Following a conference call with Judge Corley, and at her
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suggestion, the parties submit this renewed, but more detailed, request for a modification of
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existing pre-trial and trial deadlines.
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The parties have been engaged in serious settlement negotiations since May 2011.
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Substantial progress was made by late July, but two factors arose which delayed completion of
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negotiations. First, completion of those negotiations requires the involvement of a governmental
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entity that will not reconvene until mid-September. Second, the principal negotiators for each
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side had long-standing vacation schedules that made them unavailable for most of August and
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the first half of September. Facing an October 1 discovery deadline, plaintiffs’ counsel asked, as
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a condition for further settlement negotiations, for a stipulated continuance so that if settlement
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negotiations were not successful the plaintiffs were not left in the lurch. Plaintiffs indicated that
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they have a number of additional depositions, and substantial document discovery to complete,
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plus expert witness reports, all currently due October 1. In addition, plaintiffs have additional
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witnesses that will be disclosed whom defendant wishes to depose. The cost of this discovery
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would be very substantial, and would divert the parties from constructive settlement discussions.
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Defendant’s principal counsel, James Fitzgerald, does not return from his overseas
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vacation until September 17, 2011. The parties’ counsel have scheduled a face to face meeting
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on September 21 to discuss remaining settlement issues. In addition, former Magistrate Judge
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Larson, who held two settlement conferences in this case, has agreed to convene a settlement
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conference, if necessary, on September 29, 2011.
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To avoid wasting time and money on what may be unnecessary litigation, the parties
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request a 60-day extension of the existing case deadlines. The current deadlines (and proposed
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modifications) are set forth below.
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Current
Discovery Cut Off
October 3, 2011
Proposed
December 5, 2011
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A/72860666.1
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NO. C-08-2301 SBA (MDL)
SUPPLEMENTAL JOINT REQUEST TO MODIFY CASE DEADLINES
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Parties to Name Experts
October 3, 2011
December 5, 2011
Expert Discovery Cut Off
All Dispositive Motions to Be
Heard
Pre-Trial Papers Due
December 5, 2011
February 6, 2012
December 13, 2011
February 13, 2012
January 17, 2012
March 19, 2012
January 24, 2012
March 26, 2012
January 31, 2012
April 2, 2012
February 14, 2012
April 17, 2012
February 27, 2012
To Be Set by Court
Motions in Limine Due
Responses to Motions in
Limine
Pre-Trial Conference
Trial Date
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DATED: September 9, 2011, 2011
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By:
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/s/
Brad Seligman
Attorneys for Plaintiffs and the Proposed Class
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DATED: September 9, 2011
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By:
/s/
Thomas Beatty
Attorneys for Defendant
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A/72860666.1
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NO. C-08-2301 SBA (MDL)
SUPPLEMENTAL JOINT REQUEST TO MODIFY CASE DEADLINES
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GOOD CAUSE APPEARING, IT IS ORDERED THAT THE CASE DEADLINES ARE
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MODIFIED AS FOLLOWS.
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Current
New
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Discovery Cut Off
October 3, 2011
December 5, 2011
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Parties to Name Experts
October 3, 2011
December 5, 2011
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Expert Discovery Cut Off
All Dispositive Motions to Be
Heard
Pre-Trial Papers Due
December 5, 2011
February 6, 2012
December 13, 2011
February 14, 2012
January 17, 2012
March 20, 2012
January 24, 2012
March 27, 2012
January 31, 2012
April 3, 2012
February 7, 2012
April 10, 2012
February 14, 2012
April 24, 2012 at 1:00 p.m.
February 27, 2012
May 7, 2012 at 8:30 a.m.
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Motions in Limine Due
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Responses to Motions in
Limine
Replies in Support of Motions
in Limine
Pre-Trial Conference
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Trial Date
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Good cause appearing, IT IS SO ORDERED.
DATED: 9/15/11
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__________________________________
Hon. Saundra Brown Armstrong
UNITED STATES DISTRICT JUDGE
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A/72860666.1
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NO. C-08-2301 SBA (MDL)
SUPPLEMENTAL JOINT REQUEST TO MODIFY CASE DEADLINES
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