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

Filing 52

ORDER Continuing Deadlines. Discovery due by 1/16/2012. Expert Witness List due by 2/3/2012. Case Management Conference CONTINUED to 1/11/2012 01:30 PM. Case Management Statement due by 1/4/2012. Signed by Magistrate Judge Donna M. Ryu on 12/9/2011. (dmrlc1, COURT STAFF) (Filed on 12/9/2011)

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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
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
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

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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,

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Plaintiff,

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vs.

Case No.: C10-01622 DMR
STIPULATION AND PROPOSED
ORDER CONTINUING DISCOVERY
DEADLINES AS MODIFIED

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

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Defendants.

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The parties hereby stipulate by and through their undersigned counsel of record
to request that this Court continue the lay and expert witness discovery deadlines by
approximately thirty days as set for the below.
Good cause exists for the above requests, as follows:
1. At the October 11, 2011 settlement conference before Magistrate Judge
Joseph C. Spero the parties reached a settlement in principle.
2. Based on the settlement in principle the parties have stayed discovery since
October 11, 2011.
3. The parties are currently working on the details of settlement, some of which
require the Regents to seek detailed internal guidance.
4. The Regents are currently drafting a detailed settlement agreement, but have
not forwarded the draft to Mr. Hamilton
5. The Regents shall forward Mr. Hamilton the draft settlement agreement on or
before December 14, 2011.

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_________________________________________________________________________________________________________
Case No.: C10-01622 DMR
STIPULATION AND PROPOSED ORDER
RESCHEDULING THE CASE MANAGEMENT CONFERENCE
AND DISCOVERY DEADLINES
2

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6. It is anticipated that once finalized and executed, the settlement agreement
will obviate the need for further litigation in the matter.
7. The deadline to complete lay discovery and designate expert witnesses is

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currently December 14, 2011, and the deadline to complete expert witness

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discovery is January 13, 2012.

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8. 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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9. Continuing the lay discovery and expert witness disclosure deadline to
January 16, 2012 and the completion of expert discovery to February 3, 2012

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will allow the parties to focus all of their attention on settlement the 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.
PRICE AND ASSOCIATES

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DATED: December 8, 2011

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

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DATED: December 8, 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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STUBBS & LEONE

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DATED: December 8, 2011

/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.

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The deadline to complete all lay discovery and to designate expert witnesses is

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continued to January 16, 2012. The deadline to complete expert witness discovery is

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continued to February 3, 2012.

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are due February 24, 2012. All other dates previously set by the court shall remain in

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effect.

Final Pretrial Conference Statement and Trial Briefs

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The Case Management Conference scheduled for December 14, 2011 at 1:30

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p.m. has been CONTINUED to January 11, 2012 at 1:30 p.m. An updated joint Case

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Management Conference statement is due by January 4, 2012.

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DATED:

December 9, 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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