Estate of Cecilia Lam et al v. City and County of San Francisco et al

Filing 39

***PLEASE DISREGARD - SEE DOC. #40*** STIPULATION AND ORDER re 38 STIPULATION WITH PROPOSED ORDER re 18 Case Management Scheduling Order, STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE FOR EXPERT DISCOVERY filed by Adam L obsinger, Steven Haskell, Chhunmeng Tov, David Lee, Viet Ha, City and County of San Francisco Experts Discovery cutoff due by 6/30/2017. Signed by Magistrate Judge Kandis A. Westmore on 5/24/17. (sisS, COURT STAFF) (Filed on 5/24/2017) Modified on 5/24/2017 (sisS, COURT STAFF).

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DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
JAMES F. HANNAWALT, State Bar #139657
Deputy City Attorney
Fox Plaza
1390 Market Street, Sixth Floor
San Francisco, California 94102-5408
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO,
OFFICER CHHUNMENG TOV, OFFICER ADAM LOBSINGER,
OFFICER VIET HA, OFFICER DAVID LEE,
SGT. STEVEN HASKELL

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ESTATE OF CECILIA LAM, SHUT FAN
LAM, JOSEPH LAM,
Plaintiffs,

Case No. 16-CV-2594-KAW
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE DEADLINE FOR EXPERT
DISCOVERY

vs.
CITY AND COUNTY OF SAN
FRANCISCO; OFFICER CHHUNMENG
TOV; OFFICER ADAM LOBSINGER;
OFFICER VIET HA; OFFICER DAVID LEE;
SGT. STEVEN HASKELL; and DOES 6
through 25,

Trial Date:

October 2, 2017

Defendants.

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The undersigned parties, through counsel, STIPULATE and AGREE and jointly request

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modification of the Court's October 19, 2016 Case Management Order (Dkt. 18) as follows:

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Expert Discovery Cutoff: Friday June 30, 2017 (from Friday, May 26, 2017)

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All other dates, including the trial date, will remain the same.

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STIP & ORDER RE EXPT DISCOVERY DEADLINE
CASE NO. 16-CV-2594-KAW

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The parties make this request based on the following circumstances:

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1.

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Defendants filed a Motion for Summary Judgment that was submitted to the court

following oral argument on April 20, 2017.
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The parties wish to avoid the significant cost of having experts prepare for, and

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provide, expert witness deposition testimony in the event the Court grants Defendants’ dispositive

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motion.

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3.

There have been no other modifications to the portions of the Case Management order

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that this stipulation seeks to modify. No other dates will be affected by the requested changes.

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STIPULATED AND AGREED:

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Dated: May 18, 2017

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DENNIS J. HERRERA
City Attorney
CHERYL ADAMS
Chief Trial Deputy
JAMES F. HANNAWALT
Deputy City Attorney

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By:

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/s/ James F. Hannawalt
JAMES F. HANNAWALT
Attorneys for Defendants

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Dated: May 18, 2017
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CASPER MEADOWS SCHWARTZ & COOK

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By: /s/ Nicholas Casper
NICHOLAS CASPER
Attorneys for Plaintiffs

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STIP & ORDER RE EXPT DISCOVERY DEADLINE
CASE NO. 16-CV-2594-KAW

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ORDER

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Pursuant to stipulation, and for good cause appearing, IT IS ORDERED that the pre-trial

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deadlines be continued as follows:

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Expert Discovery Cutoff: Tuesday, June 30, 2017.

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All other dates, including the trial date, will remain the same.

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______________________________
HON. KANDIS WESTMORE
U.S. District Court Magistrate Judge

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STIP & ORDER RE EXPT DISCOVERY DEADLINE
CASE NO. 16-CV-2594-KAW

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