Montes v. Rafalowski et al

Filing 63

STIPULATION AND ORDER 61 to Extend Time to Conduct Expert Depositions of David Tristan and Daniel Vasquez. Signed by Judge Ronald M. Whyte on 3/28/12. (jg, COURT STAFF) (Filed on 3/28/2012)

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KAMALA D. HARRIS
Attorney General of California
MICHAEL W. JORGENSON
Supervising Deputy Attorney General
GIAM M. NGUYEN
Deputy Attorney General
State Bar No. 229236
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
Rafalowski and Clemons
IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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ROY A. MONTES (aka RAYMOND
MONTEZELLO),
Plaintiff,

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v.

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RAFALOWSKI, et al.,

C 09-0976 RMW

JOINT STIPULATION TO EXTEND
TIME TO CONDUCT EXPERT
DEPOSITIONS OF DAVID TRISTAN
AND DANIEL VASQUEZ UNDER
LOCAL RULE 6-2

Defendants. [] ORDER

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Judge

The Honorable Ronald M.
Whyte
Action Filed: 3/6/2009

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16807563.1

Joint Stip. to Extend Time to Conduct Expert Deps. (C 09-0976 RMW)

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WHEREAS, the close of expert discovery is March 16, 2012 (Docket No. 55);

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WHEREAS, Defendants Clemons and Rafalowski seek to take the deposition of Plaintiff’s

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expert, Daniel Vasquez;

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WHEREAS, Plaintiff seeks to take the deposition of Defendants’ expert, David Tristan;

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WHEREAS, due to the experts’ work schedules, there is insufficient time to conduct the

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experts’ depositions before the March 16, 2012 close of expert discovery;
THE PARTIES STIPULATE, by and through their attorneys of record, that the parties may

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notice the depositions of David Tristan and Daniel Vasquez to occur on or before March 23,

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2012, according to a schedule to be determined by the parties.

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Dated: March 6, 2012

/s/ Giam Nguyen________
GIAM M. NGUYEN
Deputy Attorney General
Attorneys for Defendants
Rafalowski and Clemons

Dated: March 6, 2012

/s/ Aaron Leiderman____
AARON LEIDERMAN
Munger, Tolles & Olson LLP
Attorneys for Plaintiff
Montes

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated:_________________________

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_______________________________________
RONALD M. WHYTE
United States District Judge

F2009311556
40541808.doc

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16807563.1

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Joint Stip. to Extend Time to Conduct Expert Deps. (C 09-0976 RMW)

CERTIFICATE OF SERVICE
Case Name:

R. Montes v. Rafalowski, et al.

No.

C 09-0976 RMW

I hereby certify that on March 7, 2012, I electronically filed the following documents with the
Clerk of the Court by using the CM/ECF system:
1. JOINT STIPULATION TO EXTEND TIME TO CONDUCT EXPERT
DEPOSITIONS OF DAVID TRISTAN AND DANIEL VASQUEZ UNDER LOCAL
RULE 6-2; [PROPOSED] ORDER
2. DECLARATION OF G. NGUYEN IN SUPPORT OF THE PARTIES’ JOINT
STIPULATION TO EXTEND TIME TO CONDUCT EXERT DEPOSITIONS
I certify that all participants in the case are registered CM/ECF users and that service will be
accomplished by the CM/ECF system.
I declare under penalty of perjury under the laws of the State of California the foregoing is true
and correct and that this declaration was executed on March 7, 2012, at San Francisco,
California.

S. Redd
Declarant
40543149.doc

/s/ S. Redd
Signature