Espinosa v. San Francisco

Filing 31

STIPULATION AND ORDER re 29 . ADMINISTRATIVE MOTION Continue the Deadline to Complete the Settlement Conference re 23 Case Management Scheduling Order STIPULATED ADMINISTRATIVE REQUEST TO CONTINUE THE DEADLINE TO COMPLETE THE SETTLE MENT CONFERENCE; DECLARATION OF NEWTON filed by City and County of San Francisco, Gino Q. Espinosa. Settlement Conference deadline continued until 3/30/18. Signed by Magistrate Judge Kandis A. Westmore on 1/11/18. (sisS, COURT STAFF) (Filed on 1/11/2018)

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DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
RENÉE E. ROSENBLIT, State Bar #304983
Deputy City Attorney
Fox Plaza
1390 Market Street, 6th Floor
San Francisco, California 94102-5408
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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GINO Q. ESPINOSA,

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Plaintiff,

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vs.

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CITY AND COUNTY OF SAN
FRANCISCO; SHERIFF VICKI L.
HENNESSY in her official capacity,

Case No. 17-cv-01766 KAW
STIPULATED ADMINISTRATIVE REQUEST
TO CONTINUE THE DEADLINE TO
COMPLETE THE SETTLEMENT
CONFERENCE; DECLARATION OF
NEWTON OLDFATHER; [PROPOSED]
ORDER
[L.R. 7-11]

Defendants.

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Trial Date:

November 5, 2018

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Admin. Req. to Continue Settlement Conference
17-cv-01766 KAW

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c:\users\imbria~1\appdata\local\temp\notes06e812\01244537.docx

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STIPULATED REQUEST TO CONTINUE SETTLEMENT CONFERENCE
The parties jointly request that the Court continue the deadline to complete the settlement

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conference. The current deadline is January 19, 2018 (Dkt. No. 23 at ¶ 4). The parties request that the

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Court extent this deadline to March 30, 2018. The parties need additional time to complete

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depositions. The parties have served and responded to written discovery, but the parties have had

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difficulty scheduling the necessary depositions of plaintiff and San Francisco Sheriff Deputies.

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The parties therefore jointly request that the Court continue the deadline to complete the
settlement conference to March 30, 2018.

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Dated: January 8, 2018

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DENNIS J. HERRERA
City Attorney
CHERYL ADAMS
Chief Trial Deputy
NEWTON OLDFATHER
Deputy City Attorney

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By:

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/s/ Newton Oldfather
NEWTON OLDFATHER
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO

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By

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/s/ Che L. Hashim
CHE L. HASHIM
Attorney for Plaintiff
GINO ESPINOZA

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Admin. Req. to Continue Settlement Conference
17-cv-01766 KAW

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DECLARATION OF NEWTON OLDFATHER

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I, NEWTON OLDFATHER, declare:

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1.

I am a Deputy City Attorney and am assisting the attorney of record Renee Erickson

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representing the City and County of San Francisco. I am familiar with this litigation and make this

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declaration of my own personal knowledge and review of the docket, and if called upon, could testify

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competently thereto.

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2.

The parties have been attempting to schedule the deposition of the plaintiff and San

Francisco Sheriff Deputies but have been unable to do so.
3.

On January 8, 2017, I spoke to plaintiff’s attorney, Che L. Hashim, and we agreed that

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it would be best to ask that the Court continue the deadline to complete the settlement conference so as

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to provide enough time to complete the depositions. He provided me his permission to electronically

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sign for him.

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I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct, and this declaration is executed on January 8, 2018 at San Francisco, California.

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/s/ Newton Oldfather
NEWTON OLDFATHER

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Admin. Req. to Continue Settlement Conference
17-cv-01766 KAW

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[PROPOSED] ORDER

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PURSUANT TO A STIPULATED REQUEST AND FOR GOOD CAUSE APPEARING, IT

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IS ORDERED that the deadline to complete a settlement conference in this matter is continued to

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March 30, 2018.

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Dated: ________________________
1/11/18

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_________________________________________
HONORABLE KANDIS A. WESTMORE
United States Magistrate Judge

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Admin. Req. to Continue Settlement Conference
17-cv-01766 KAW

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