Franklin v. City of San Leandro et al

Filing 50

ORDER by Judge Haywood S. Gilliam, Jr. Granting 49 Stipulation to Extend Expert Discovery Deadlines.Opening Reports due by 4/11/2019; Rebuttal Reports due by 4/26/2019; and Close of Expert Discovery due by 5/10/2019. (ndrS, COURT STAFF) (Filed on 3/11/2019)

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Gregory M. Fox, State Bar No. 070876
Joanne Tran, State Bar No. 294402
Heidi G. Kim, State Bar No. 306641
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant
OFFICER DENNIS MALLY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RON FRANKLIN, an individual

Case No. 4:17-cv-00789-HSG

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Plaintiff,

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STIPULATION AND ORDER TO EXTEND
EXPERT DISCOVERY DEADLINES

v.
CITY OF SAN LEANDRO, a municipal
corporation; DENNIS MALLY, individually
and in his capacity as an officer for the San
Leandro Police Department; and DOES 1-25,
inclusive, individually, jointly and severally,
Defendants.

Hon. Haywood S. Gilliam, Jr.

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Pursuant to Federal Rules of Civil Procedure Rule 16(b)(4), and the Scheduling Order issued by

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United States District Judge Haywood S, Gilliam Jr. on September 27, 2018 (the “Scheduling Order”),

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(Dkt. No. 37.) Plaintiff RON FFRANKLIN and Defendant DENNIS MALLY by and through

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undersigned counsel, hereby jointly stipulate and move to extend expert discovery deadlines for good

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cause as follows:
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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES
Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG

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1.

Pursuant to the Scheduling Order, the cut-off for:

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

Exchange of opening expert reports is March 12, 2019.

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

Exchange of rebuttal expert reports is March 27, 2019.

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

Close of expert discovery is April 11, 2019.

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2.

The parties have met and conferred and agree that an additional 30 days extension is

necessary to permit the parties to sufficiently complete expert discovery.
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This is the first request to continue expert discovery deadlines. This extension will not

affect the trial date or any other dates previously set by the Court.
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For the reasons set forth above, the parties respectfully request that this Court continue the

previously set expert discovery deadlines as follows:

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

Exchange of opening expert reports to April 11, 2019.

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

Exchange of rebuttal expert reports to April 26, 2019.

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

Close of expert discovery to May 10, 2019.

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IT IS SO STIPULATED AND REQUESTED THROUGH THE PARTIES’ COUNSELS OF
RECORD.

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Dated: March 8, 2019

BERTRAND, FOX, ELLIOT, OSMAN & WENZEL

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By:

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/s/ Joanne Tran
Gregory M. Fox
Joanne Tran
Heidi Kim
Attorneys for Defendant
OFFICER DENNIS MALLY

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Dated: March 8, 2019

LAW OFFICES OF JOHN L. BURRIS
By:

/s/ K. Chike Odiwe
John L. Burris
DeWitt Lacy
K. Chike Odiwe
Attorneys for Plaintiff
RON FRANKLIN

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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES
Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG

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ATTORNEY ATTESTATION

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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conformed signature (“/s/”) within this E-filed document or have been authorized by Plaintiff’s counsel

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to show their signature on this document as /s/.

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Dated: March 8, 2019

By:

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/s/ Joanne Tran
Joanne Tran

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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES
Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG

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ORDER
GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the
following deadlines have been extended to 30 days:

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

Exchange of opening expert reports is April 11, 2019

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

Exchange of rebuttal expert reports is April 26, 2019.

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

Close of expert discovery is May 10, 2019.

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IT IS SO ORDERED.

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Dated: March 11, 2019
Hon. Haywood S. Gilliam, Jr.
UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES
Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG