Cruz v. Ahmed

Filing 71

STIPULATION AND ORDER TO EXTEND DEADLINE re 70 . STIPULATION WITH PROPOSED ORDER filed by Zahed Uddin Ahmed, Santiago Cruz. Amended Pleadings due by 1/31/2018. Signed by Magistrate Judge Kandis A. Westmore on 11/16/17. (sisS, COURT STAFF) (Filed on 11/16/2017)

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R. MORGAN GILHULY (SBN 133659; [e-mail])
JULIA R. GRAESER (SBN 294117; [e-mail])
BARG COFFIN LEWIS & TRAPP, LLP
350 California Street, 22nd Floor
San Francisco, California 94104-1435
Telephone: [phone]
Fax: [phone]

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Attorneys for Plaintiff SANTIAGO CRUZ

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SANTIAGO CRUZ,

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Case No. 4:15-cv-01855-KAW

Plaintiff,
STIPULATION AND [PROPOSED]
ORDER

v.
ZAHED UDDIN AHMED,
Defendant.

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WHEREAS, on June 23, 2017, the Court issued a Case Management and Pretrial Order

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for Jury Trial, which included October 27, 2017 as the last day to amend pleadings in the case;

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WHEREAS, on October 26, 2017, the parties filed a stipulation and proposed order to

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extend the deadline to amend the pleadings until December 22, 2017, on grounds that document

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productions by California Department of Corrections and Rehabilitation and California

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Correctional Health Care Services in response to plaintiff’s subpoenas were still ongoing and the

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parties anticipated depositions in late November or December;

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WHEREAS, on October 31, 2017, this Court granted the parties’ proposed order to
extend the deadline to amend pleadings to December 22, 2017;
WHEREAS, California Department of Corrections and Rehabilitation’s production of
documents in response to Plaintiff’s subpoena for business records is not yet complete;
WHEREAS, counsel for Defendant is now involved in a trial in early December and has
STIPULATION AND [PROPOSED] ORDER
U.S.D.C Case No. Civ. 4:15-cv-01855-KAW

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requested that depositions be scheduled in early January to accommodate his very limited

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availability in November and December;

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WHEREAS, Plaintiff’s counsel is willing to accommodate defense counsel’s trial

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schedule, so long as Plaintiff is not prejudiced from filing a First Amended Complaint to add

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supervisory officers, should the facts support the addition of any such parties;

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WHEREAS, the parties have agreed to further extend the deadline to amend the pleadings

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until January 31, 2018 in order to accommodate defense counsel’s schedule and respectfully

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request that this Court so order.

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IT IS SO STIPULATED.

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Dated: November 14, 2017

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Respectfully submitted,
R. MORGAN GILHULY
JULIA R. GRAESER
BARG COFFIN LEWIS & TRAPP, LLP

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/s/ Julia R. Graeser

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Attorneys for Plaintiff Santiago Cruz

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Dated: November 14, 2017

Respectfully submitted,
XAVIER BECERRA
Attorney General of California
JEFFREY R. VINCENT
Supervising Deputy Attorney General

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/s/ Rohit Kodical

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Attorneys for Defendant Dr. Ahmed

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IT IS SO ORDERED.

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11/16/17
Dated: _________

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_____________________________
The Honorable Kandis Westmore

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STIPULATION AND [PROPOSED] ORDER
U.S.D.C Case No. Civ. 4:15-cv-01855-KAW

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