Cox et al v. The County of Alameda et al

Filing 39

STIPULATION AND ORDER AS MODIFIED re 38 STIPULATION WITH PROPOSED ORDER re 36 Clerks Notice, 26 Case Management Scheduling Order, filed by Ryan Cox, The County of Alameda, City of Dublin, Blane Cox, Marc G. Dinis Case Management Statement due by 9/2/2014. Case Management Conference set for 9/9/2014 01:30 PM. Signed by Magistrate Judge Kandis A. Westmore on 8/15/14. (sisS, COURT STAFF) (Filed on 8/18/2014)

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Randy Sullivan (229326)
[e-mail]
PATTON & SULLIVAN LLP
6600 Koll Center Parkway, Suite 250
Pleasanton, California 94566-8058
925-600-1800 Phone
925-600-1802 Fax
Attorneys for Plaintiffs,
Ryan Cox and Blane Cox

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RYAN COX, and BLANE COX,

Case: 4:13-cv-04449-KAW

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Plaintiffs,

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v.
THE COUNTY OF ALAMEDA, a
municipal corporation; the CITY OF
DUBLIN, a municipal corporation;
DEPUTY MARC G. DINIS; and DOES
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STIPULATION AND
[PROPOSED] ORDER TO
CONTINUE EXPERT
DEADLINES AND CONTINUE
THE CASE MANAGEMENT
CONFERENCE
Complaint Filed: September 25, 2013
Trial Date: February 9, 2015

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Defendants.

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IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES,
through their attorneys of record that:
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The parties wish to continue the non-expert discovery by a week to

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September 16, 2014, and continue the expert deadlines by four weeks. However,

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the parties wish to maintain all other deadlines, including, but not limited to, the

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last day to hear a motion for summary judgment, the pretrial conference, and trial

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STIPULATION AND [PROPOSED] ORDER

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date as set forth in the January 7, 2014, Case Management Conference and Order

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for Jury Trial.

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2.

The parties also respectfully request a continuance of the Case

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Management Conference until after the August 27, 2014, Settlement Conference

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scheduled with the Honorable Maria-Elena James. The parties have met and

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conferred, and have agreed to September 2, 2014, as the new Case Management

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Conference date.

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3.

The parties respectfully request the continuance because there is

currently pending an August 27, 2014, Settlement Conference scheduled with the

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Honorable Maria-Elena James. By continuing the expert deadlines the parties

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will save substantial sums that can be applied towards a settlement of the matter,

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thereby increasing the likelihood of settlement.

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4.

The parties respectfully request that any modification of the expert

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deadlines still maintain the current trial date, pretrial conference date, and the last

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day to hear a motion for summary judgment.

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5.

The parties respectfully request that the deadline to disclose experts

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and expert reports be continued four weeks from September 9, 2014, to

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October 7, 2014.

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6.

The parties respectfully request that the last day to disclose rebuttal

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experts and their reports be continued from September 23, 2014, to October 21,

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2014.

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7.

The parties respectfully request that the expert discovery cutoff,

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including any testing or inspections be continued four weeks from

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October 7, 2014, to November 4, 2014.

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STIPULATION AND [PROPOSED] ORDER

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Dated: August 14, 2014

PATTON & SULLIVAN LLP

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By:

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/s/Randy Sullivan
Randy Sullivan

Attorneys for Plaintiffs
Dated: August 14, 2014

HAAPALA, THOMPSON & ABERN, LLP

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By:

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/s/Rebecca S. Widen
Rebecca S. Widen

Attorneys for Defendants

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ORDER

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Good cause appearing and based upon the foregoing Stipulation:

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IT IS ORDERED that the Court shall modify the January 7, 2014, Case
Management Conference and Order for Jury Trial, deadlines as follows:

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1.

September 16, 2015.

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2.

The last day to disclose experts and expert reports shall be

October 7, 2014.

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The last day to complete all non-expert discovery shall be

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The last day to disclose rebuttal experts and their reports shall be

October 21, 2014.

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4.

The expert discovery cutoff, including any testing or inspections

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deadlines shall be continued to November 4, 2014.

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STIPULATION AND [PROPOSED] ORDER

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5.

It is further ordered that the Case Management Conference currently

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scheduled for August 19, 2014 be rescheduled to September 9, 2014, at

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1:30 p.m., after the Mandatory Settlement Conference scheduled for August 27,

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2014.

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Dated:

8/15/14

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Kandis A. Westmore
United States Magistrate Judge

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STIPULATION AND [PROPOSED] ORDER