Hamilton v. The Regents of the University of California et al

Filing 49

ORDER re 48 Stipulation. Further Case Management Conference set for 12/14/2011 01:30 PM. Case Management Statement due by 12/7/2011. Discovery due by 12/14/2011. Expert Witness List due by 12/14/2011. Expert Discovery due by 1/13/2012. Signed by Magistrate Judge Donna M. Ryu on 11/01/2011. (dmrlc1, COURT STAFF) (Filed on 11/1/2011)

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LOUIS A. LEONE, ESQ. (SBN: 099874)
CLAUDIA LEED, ESQ. (SBN: 122676)
STUBBS & LEONE
A Professional Corporation
2175 N. California Blvd., Suite 900
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile:
[phone]
E-mail: [e-mail]
[e-mail]

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Attorneys for Defendants
THE REGENTS OF THE UNIVERSITY OF CALIFORNIA,
PAMELA E. ROSKOWSKI, JON EASTERBROOK, and
BARNEY RIVERA
PAMELA Y. PRICE, ESQ. (SBN:107713)
PRICE AND ASSOCIATES
901 Clay Street
Oakland, California 94607
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiff
REGGIE HAMILTON

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CURTIS E. ALLEN, ESQ. (SBN: 187748)
LAW OFFICE OF CURTIS ALLEN
303 Twin Dolphin Drive, Sixth Floor
Redwood City, California 94065
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
REGGIE HAMILTON

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_________________________________________________________________________________________________________
Case No.: C10-01622 DMR
STIPULATION AND PROPOSED ORDER
RESCHEDULING THE CASE MANAGEMENT CONFERENCE
AND DISCOVERY DEADLINES
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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REGGIE HAMILTON,
Plaintiff,

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vs.

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Case No.: C10-01622 DMR
STIPULATION AND PROPOSED
ORDER RESCHEDULING THE CASE
MANAGEMENT CONFERENCE AND
CONTINUING DISCOVERY
DEADLINES AS MODIFIED

THE REGENTS OF THE UNIVERSITY OF
CALIFORNIA, PAMELA E. ROSKOWSKI,
JON EASTERBROOK, BARNEY RIVERA
and DOES 1 through 15,
Defendants.

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The parties to the above captioned action hereby stipulate by and through their

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undersigned counsel of record to request that this court continue the 1:30 p.m.

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November 2, 2011 Case Management Conference to 1:30 p.m. December 14, 2011, or

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as soon thereafter as it may please the Court.

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The parties also hereby stipulate by and through their undersigned counsel of

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record to request that this court continue the lay and expert witness discovery deadlines

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by approximately thirty days as set for the below.

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Good cause exists for the above requests, as follows:

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1. At the October 11, 2011 settlement conference before Magistrate Judge

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Joseph C. Spero the parties reached a settlement in principle.
2. At the settlement conference the parties set a three week check-in time
(November 1, 2011) with Magistrate Judge Spero.
3. On October 11, 2011 the parties stayed ongoing discovery for three weeks to
November 1, 2011 in light of the settlement in principle.
4. The parties are currently working on the details of settlement, some of which
require the Regents to seek detailed internal guidance.
_________________________________________________________________________________________________________
Case No.: C10-01622 DMR
STIPULATION AND PROPOSED ORDER
RESCHEDULING THE CASE MANAGEMENT CONFERENCE
AND DISCOVERY DEADLINES
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5. It is anticipated that a completed settlement agreement will be executed by all

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parties on or before November 20, 2011, and that the completed settlement

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agreement will obviate the need for further litigation in the matter.

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6. The deadline to complete lay discovery and designate expert witnesses is

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currently November 7, 2011, and the deadline to complete expert witness

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discovery is December 5, 2011.

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7. The last day to hear dispositive motions is January 5, 2012 and the Final

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Pretrial Conference Statement and Trial Briefs are due February 4, 2012.

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8. Continuing the lay discovery and expert witness disclosure deadline to

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December 14, 2011 and the completion of expert discovery to January 13,

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2012 will allow the parties to focus all of their attention on settlement the

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matter.

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Given all of the above, a continuance of the Case Management Conference and

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Discovery deadlines will serve judicial economy and spare the parties considerable and

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likely needless discovery-related expense.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: October 31, 2011

PRICE AND ASSOCIATES

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/S/
_______
PAMELA Y. PRICE, ESQ.
Attorneys for Plaintiff REGGIE
HAMILTON

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DATED: October 31, 2011

LAW OFFICE OF CURTIS E. ALLEN

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___________/S/__________________
CURTIS E. ALLEN, ESQ.
Attorneys for Plaintiff REGGIE
HAMILTON

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_________________________________________________________________________________________________________
Case No.: C10-01622 DMR
STIPULATION AND PROPOSED ORDER
RESCHEDULING THE CASE MANAGEMENT CONFERENCE
AND DISCOVERY DEADLINES
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DATED: October 31, 2011

STUBBS & LEONE

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/S/
CLAUDIA LEED, ESQ.
Attorneys for Defendants THE
REGENTS OF THE UNIVERSITY OF
CALIFORNIA,
PAMELA E. ROSKOWSKI, JON
EASTERBROOK, and BARNEY
RIVERA

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
The 1:30 p.m. November 2, 2011 Case Management Conference is continued to

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1:30 p.m. December 14, 2011. An updated joint Case Management Conference

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statement shall be filed by December 7, 2011. The deadline to complete all lay

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discovery and to designate expert witnesses is continued to December 14, 2011. The

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deadline to complete expert witness discovery is continued to January 13, 2012.

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DATED:

November 1, 2011
DONNA M. RYU
United States Magistrate Judge

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_________________________________________________________________________________________________________
Case No.: C10-01622 DMR
STIPULATION AND PROPOSED ORDER
RESCHEDULING THE CASE MANAGEMENT CONFERENCE
AND DISCOVERY DEADLINES
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