Mou v. City of San Jose et al

Filing 574

Mou v. City of San Jose et al

Doc. 574

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STEPHEN D. SCHEAR State Bar No. 83806 JANA CARTER State Bar No. 209110 CARTER & SCHEAR 2831 Telegraph Avenue Oakland, California 94609 [phone] Attorneys for Plaintiff TUMEKA GODWIN

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
TUMEKA GODWIN, ) ) Plaintiff, ) ) vs. ) ) DEPUTY HUGHES, CITY AND COUNTY) OF SAN FRANCISCO, SHERIFF ) MICHAEL HENNESEY, and DOES 1 ) THROUGH 10, INCLUSIVE ) ) Defendants. ) No. C 02-05631 JSW STIPULATED REQUEST FOR ORDER CHANGING TIME; DECLARATION; AND PROPOSED ORDER Pursuant to Civil Local Rule 6-2.

) ) STIPULATED REQUEST FOR ORDER CHANGING TIME

Pursuant to the Northern District's Civil Local Rule 6-2, the parties hereby stipulate and request that the court order extensions of time for all deadlines in the above case. The reasons for this request are set forth in the declaration of Jana Carter attached hereto. The parties stipulate and request the court to change time as set forth below: (1) Current trial date: Modified trial date: (2) Current last day to hear dispositive motions: Modified date to hear dispositive motions:
STIPULATION FOR CHANGING TIME, DECLARATION IN SUPPORT AND PROPOSED ORDER

July 26, 2004 March 14, 2005 June 18, 2004 January 28, 2005
C 02-05631 JSW

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Dockets.Justia.com

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(3)

Current discovery closure: Modified date for discovery closure:

April 3, 2004 December 3, 2004 February 17, 2004 May 3, 2004

(4)

Current ENE deadline: Modified ENE deadline:

IT IS SO STIPULATED. Dated: March 2, 2004 _/s/____________________ Jana Carter Attorney for Plaintiff Tumeka Godwin _/s/___________________ Evan Ackiron Deputy City Attorney Attorney for Defendants San Francisco and Sheriff Hennessey

Dated: March 4, 2004

IT IS SO ORDERED. Dated: _______________ ______________________________ The Honorable Jeffrey S. White UNITED STATES DISTRICT JUDGE

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STIPULATION FOR CHANGING TIME, DECLARATION -2IN SUPPORT AND PROPOSED ORDER C 02-05631 JSW

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DECLARATION IN SUPPORT OF STIPULATED REQUEST FOR ORDER CHANGING TIME PURSUANT TO CIVIL LOCAL RULE 6-2(a) I, Jana Carter, declare as follows: 1. I am an attorney duly licensed to practice law in this Court and I represent the

plaintiff, Tumeka Godwin, in this lawsuit. If called to testify, I would and could testify competently to the matters set forth below. 2. I plan to be on maternity leave from June 21, 2004 through September 24, 2004,

although I may be able to work part-time during the latter part of that time. However, the earlier part of my maternity leave overlaps several of the deadlines in this case, including the current trial date and the last day to hear dispositive motions. As a result, the parties have agreed to extensions of time on the trial date until March 14, 2005 and the last day to hear dispositive motions until January 28, 2005. 3. The ENE, originally scheduled for August 2003 has not yet taken place. A new

ENE evaluator has been assigned and after conferring with the parties, requested that the parties seek a continuance of the ENE deadline until at least April 16, 2004. The parties have agreed to conduct additional discovery before the ENE, which is currently scheduled for April 16, 2003. Thus, the parties seek to have the ENE deadline extended to May 3, 2004. 4. The parties are currently conducting discovery. The parties request that the

discovery deadline be extended until December 3, 2004, to allow for the completion of discovery, given my scheduled maternity leave. 5. No previous time extensions have been requested, with the exception of several

extensions of the ENE deadline. 6. The effect the proposed time modifications will have on the schedule for the case

will be a delay of approximately eight months. DATED: March 2, 2004 __/s/ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ Jana Carter CARTER & SCHEAR Attorney for Plaintiff Tumeka Godwin
C 02-05631 JSW

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STIPULATION FOR CHANGING TIME, DECLARATION -3IN SUPPORT AND PROPOSED ORDER