Barber v. City of Crescent City et al

Filing 77

ORDER re 76 Granting Stipulation To Continue Discovery Deadlines. Signed by Judge Claudia Wilken on 9/21/2010. (ndr, COURT STAFF) (Filed on 9/21/2010)

Barber v. City of Crescent City et al

Doc. 77

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LIEBERT CASSIDY WHITMORE
A Professional Law Corporation 153 Townsend Street, Suite 520 San Francisco, CA 94107

Richard C. Bolanos, Bar No. 111343 [e-mail] Morin I, Jacob, Bar No. 204598 [e-mail] LIEBERT CASSIDY WHITMORE A Professional Law Corporation 153 Townsend Street, Suite 520 San Francisco, CA 94107 Telephone: Facsimile: [phone] [phone]

Attorneys for Defendants CITY OF CRESCENT CITY and DOUGLAS PLACK UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 v. MICHELLE BARBER, Plaintiff,

Case No. 08-CV-04883-CW STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DEADLINES

CITY OF CRESCENT CITY, a California Municipality; DOUGLAS PLACK; and ERIC CAPON; and DOES 1-100 and Each of Them, Inclusive, Defendants.

BY AND THROUGH THEIR COUNSEL PLAINTIFF AND DEFENDANTS HEREBY STIPULATE AS FOLLOWS: Whereas, Plaintiff's counsel, Abraham Goldman, is deaf and depends on bilateral cochlear implants for his hearing; Whereas, starting in May, 2010, Mr. Goldman's right implant became infected; Whereas, after four courses of antibiotic treatment, surgery was eventually required in August, 2010, as the implant had migrated out of place; Whereas, the post operative treatment is continuing, and Mr. Goldman's implant will not
142292.1 CR015-005

CASE NO. 08-CV-04883-CW STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DEADLINES
Dockets.Justia.com

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LIEBERT CASSIDY WHITMORE
A Professional Law Corporation 153 Townsend Street, Suite 520 San Francisco, CA 94107

be activated until some time in September or October 2010; Whereas, this unexpected illness, surgery and recovery has caused delays in completing fact and expert discovery and trial preparation; Whereas, as a result of Mr. Goldman's continuing and ongoing health issues and upcoming medical appointments, the parties have had to continue the previously scheduled private mediation set before Judge Ronald Sabraw from September 25, 2010 to November 29, 2010; The parties respectfully submit the following stipulation: 1. The October 12, 2010 expert disclosure deadline is continued to December 16, 2010; 2. The November 30, 2010 discovery cut-off is continued to January 21, 2011; and 3. The January 4, 2011 expert discovery cut-off is continued to January 21, 2011. Dated: September 17, 2010 LIEBERT CASSIDY WHITMORE

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By:

/s/ Morin I. Jacob Morin I. Jacob Attorneys for Defendants

Dated: September 17, 2010

LAW OFFICES OF ABRAHAM GOLDMAN

By:

/s/ Abraham Goldman Abraham Goldman Attorneys for Plaintiff

ORDER It is so ordered.

9/21/2010 Date:_____________________

____________________________________ The Honorable Claudia Wilken

142292.1 CR015-005

CASE NO. 08-CV-04883-CW STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DEADLINES

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