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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1 4 R. MORGAN GILHULY (SBN 133659; JULIA R. GRAESER (SBN 294117; BARG COFFIN LEWIS & TRAPP, LLP 350 California Street, 22nd Floor San Francisco, California 94104-1435 Telephone: (415) 228-5400 Fax: (415) 228-5450 5 Attorneys for Plaintiff SANTIAGO CRUZ 2 3 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 SANTIAGO CRUZ, 12 13 14 15 Case No. 4:15-cv-01855-KAW Plaintiff, STIPULATION AND [PROPOSED] ORDER v. ZAHED UDDIN AHMED, Defendant. 16 17 WHEREAS, on June 23, 2017, the Court issued a Case Management and Pretrial Order 18 for Jury Trial, which included October 27, 2017 as the last day to amend pleadings in the case; 19 WHEREAS, on October 26, 2017, the parties filed a stipulation and proposed order to 20 extend the deadline to amend the pleadings until December 22, 2017, on grounds that document 21 productions by California Department of Corrections and Rehabilitation and California 22 Correctional Health Care Services in response to plaintiff’s subpoenas were still ongoing and the 23 parties anticipated depositions in late November or December; 24 25 26 27 28 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 3089595.v1 1 requested that depositions be scheduled in early January to accommodate his very limited 2 availability in November and December; 3 WHEREAS, Plaintiff’s counsel is willing to accommodate defense counsel’s trial 4 schedule, so long as Plaintiff is not prejudiced from filing a First Amended Complaint to add 5 supervisory officers, should the facts support the addition of any such parties; 6 WHEREAS, the parties have agreed to further extend the deadline to amend the pleadings 7 until January 31, 2018 in order to accommodate defense counsel’s schedule and respectfully 8 request that this Court so order. 9 IT IS SO STIPULATED. 10 11 Dated: November 14, 2017 12 Respectfully submitted, R. MORGAN GILHULY JULIA R. GRAESER BARG COFFIN LEWIS & TRAPP, LLP 13 14 15 /s/ Julia R. Graeser 16 Attorneys for Plaintiff Santiago Cruz 17 Dated: November 14, 2017 Respectfully submitted, XAVIER BECERRA Attorney General of California JEFFREY R. VINCENT Supervising Deputy Attorney General 18 19 20 /s/ Rohit Kodical 21 Attorneys for Defendant Dr. Ahmed 22 23 IT IS SO ORDERED. 24 25 11/16/17 Dated: _________ 26 _____________________________ The Honorable Kandis Westmore 27 28 2 STIPULATION AND [PROPOSED] ORDER U.S.D.C Case No. Civ. 4:15-cv-01855-KAW 3089595.v1

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