S.S. v. Oakland Unified School District et al

Filing 33

ORDER by Judge Haywood S. Gilliam, Jr. Granting 32 Stipulation AMENDING SCHEDULING ORDER. (ndrS, COURT STAFF) (Filed on 7/7/2017)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18

LOUIS A. LEONE, ESQ. (SBN: 099874)
KATHERINE A. ALBERTS (SBN: 212825)
CLAUDIA LEED, ESQ. (SBN: 122676)
LEONE & ALBERTS
A Professional Corporation
2175 N. California Blvd., Suite 900
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile:
[phone]
E-mail:
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendant
OAKLAND UNIFIED SCHOOL DISTRICT
JAY JAMBECK, ESQ. (SBN: 226018)
MANDY LEIGH, ESQ. (SBN: 225748)
Damien Troutman, ESQ. (SBN: 286616)
LEIGH LAW GROUP, PC
870 Market Street, Suite 1157
San Francisco, CA
Telephone: [phone]
Facsimile:
[phone]
E-mail:
[e-mail]
Attorneys for Plaintiff
S.S. (a minor) by and through, JILL and KRIS
SULKA, as Guardians ad Litem for S.S.

19

UNITED STATES DISTRICT COURT

20

NORTHERN DISTRICT OF CALIFORNIA

21
22
23
24

S.S. (a minor) by and through, JILL and
KRIS SULKA, as Guardians ad Litem for
S.S.,
Plaintiff,

Case No.: 16-cv-05632-HSG

STIPULATION AND AMENDED
SCHEDULING ORDER

vs.

25
26
27
28

OAKLAND UNIFIED SCHOOL DISTRICT
And Does 1-30, inclusive,
Defendants.
_________________________________________________________________________________________________________
STIPULATION AND AMENDED
Case No.: 16-cv-05632-HSG
SCHEDULING ORDER
1

The parties to the above captioned litigation hereby stipulate by and through

1
2

their undersigned counsel of record to request that the Court order the following

3

revised scheduling order in this matter:

4

16

Litigation Event
Close of Fact Discovery
Disclosure of experts and
Rule 26 expert reports
pursuant to FRCP Rule 26
2 (A) and (B)
Last Day to Hear
Dispositive Motions
Disclosure of
supplemental rebuttal
expert reports
Deadline to complete
discovery and depositions
of therapists, medical and
psychological care
providers
Last day to complete
expert discovery
Pretrial Conference

17

Jury Trial

5
6
7
8
9
10
11
12
13
14
15

Current Date
July 14, 2017
None ordered

Proposed Date
August 11, 2017
September 14, 2017 by 5:00
p.m. (served electronically)

September 7, 2017
at 2:00 p.m.
None ordered

None ordered

September 21, 2017 at 2:00
p.m.
September 25, 2017 by 5:00
p.m.
(served electronically)
October 13, 2017

October 13, 2017

No change proposed

November 14, 2017 at
3:00 p.m.
December 4, 2017

No change proposed
No change proposed

18

Good cause exists for the requested amendment to the scheduling order on

19

several grounds. The scheduling of the depositions of several witnesses before the

20

current fact discovery cut off is not possible due to a combination of their unavailability

21

and the pre-planned family vacations of counsel for both parties. The amended

22

schedule permits the parties to hold off on briefing of defendant’s motion for summary

23

judgment until after the Mediation scheduled for July 26, 2017. The proposed amended

24

schedule does not disrupt deadlines to complete expert disclosure, or the dates of the

25

Pre-trial Conference and Trial.

26

///

27

///

28

_________________________________________________________________________________________________________
STIPULATION AND AMENDED
Case No.: 16-cv-05632-HSG
SCHEDULING ORDER
2

1
2

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: July 5, 2017

3

LEIGH LAW GROUP
By:

4
5
6
7

Dated: July 5, 2017

8

10
11
12
13
14

LEONE & ALBERTS
By:

9

/s/, Jay Jambeck
JAY JAMBECK, ESQ.
Attorneys for Plaintiff
S.S. (a minor) by and through, JILL and KRIS
SULKA, as Guardians ad Litem for S.S.

/s/, Katherine Alberts
LOUIS A. LEONE, ESQ.
KATHERINE A. ALBERTS, ESQ.
CLAUDIA LEED, ESQ.
Attorneys for Defendant
OAKLAND UNIFIED SCHOOL DISTRICT
ORDER

Pursuant to the stipulation of the parties, and good cause appearing, the
scheduling order in this matter is hereby amended as follows:

15
16

Litigation Event
Close of Fact Discovery

Current Date
July 14, 2017

Proposed Date
August 11, 2017

Disclosure of experts and
Rule 26 expert reports
pursuant to FRCP Rule 26
2 (A) and (B)

None ordered

September 14, 2017 by 5:00
p.m. (served electronically)

Last Day to Hear
Dispositive Motions

September 7, 2017
at 2:00 p.m.

September 21, 2017 at 2:00
p.m.

Disclosure of
supplemental rebuttal
expert reports

None ordered

September 25, 2017 by 5:00
p.m. (served electronically)

Deadline to complete
discovery and depositions
of therapists, medical and
psychological care
providers

None ordered

October 13, 2017

17
18
19
20
21
22
23
24
25
26
27
28

_________________________________________________________________________________________________________
STIPULATION AND AMENDED
Case No.: 16-cv-05632-HSG
SCHEDULING ORDER
3

Last da to complete
ay
expert discovery

October 13 2017
3,

No chan propose
nge
ed

Pretrial Conferenc
l
ce

1

November 14, 2017
r
at 3:00 p.m
m.
December 4, 2017
r

No chan propose
nge
ed

2
3
4
5
6
7

Jury Tr
rial

No chan propose
nge
ed

IT IS SO OR
T
RDERED:
Dated: July 7, 2017
J
7

_________
_________
__________
_________
____
HON. HAY
YWOOD S. GILLIAM, J
JR.
UNITED S
STATES DIS
STRICT CO
OURT JUDGE

8
9
10
0
11
2
12
3
13
14
4
15
5
16
6
17
7
18
8
19
9
20
0
21
22
2
3
23
24
4
25
5
26
6
27
7
28
8

__________
______________
______________
______________
______________
______________
______________
______________
______
STIPULATIO AND AMEND
ON
DED
Case No.: 1
16-cv-05632-H
HSG
SCHEDULIN ORDER
NG
4