Medina v. Dr. Claire Williams, MD et al

Filing 130

STIPULATION AND ORDER 129 to Extend Case Management Deadlines: Jury Trial set for 6/30/2014 01:30 PM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Motion Hearing set for 5/22/2014 09:00 AM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Pretrial Conference set for 6/19/2014 02:00 PM in Courtroom 6, 4th Floor, San Jose before Hon. Ronald M. Whyte. Discovery cutoff 11/22/2013. Signed by Judge Ronald M. Whyte on 7/29/13. (jg, COURT STAFF) (Filed on 7/29/2013)

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LATHAM & WATKINS LLP
Timothy P. Crudo (Bar No. 143835)
Evangeline A.Z. Burbidge (Bar No. 266966)
Christina E. Namikas (Bar No. 288521)
505 Montgomery Street, Suite 2000
San Francisco, California 94111-6538
Telephone: [phone]
Facsimile: +1.415.395.8095
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff
FRANCISCO J. MEDINA

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KAMALA D. HARRIS
Attorney General of California
DANIELLE F. O’BANNON
Supervising Deputy Attorney General
MARISA Y. KIRSCHENBAUER
Deputy Attorney General
SARA D. VAN LOH (Bar No. 264704)
Deputy Attorney General
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
C. WILLIAMS AND M. SAYRE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FRANCISCO J. MEDINA,

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Plaintiff,
v.
DR. CLAIRE WILLIAMS, et. al.,

CASE NO. C 10-03610 RMW
STIPULATION AND [PROPOSED] ORDER
TO EXTEND CASE MANAGEMENT
DEADLINES
Trial Date: March 17, 2014
Judge:
Honorable Ronald M. Whyte

Defendants.

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ATTORNEYS AT LAW
SAN FRANCISCO

STIPULATION AND [PROPOSED] ORDER TO
EXTEND CASE MANAGEMENT DEADLINES
CASE NO. C 10-03610 RMW

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WHEREAS, an initial Federal Rule of Civil Procedure Rule 26(f) Case Management
Conference was held on January 25, 2013;

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WHEREAS, this Court issued a Case Management Scheduling Order on March 18,

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2013, in which it set forth deadlines with respect to discovery, dispositive motions, pretrial

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conference, and trial;

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WHEREAS, that Order directed the parties to exchange initial disclosures pursuant to

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Federal Rule of Civil Procedure 26 on or before 14 days after the Court issued an order regarding

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the status of Defendant Sayre as a party to this suit;

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WHEREAS, the status of Defendant Sayre remains undetermined;

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WHEREAS, discovery has remained stayed pending the Court’s ruling on Defendant
Sayre;
WHEREAS, the current deadlines with respect to discovery, dispositive motions, pretrial

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conference, and trial, are no longer feasible in light of the continuing stay of discovery and the

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unresolved status of Defendant Sayre, and;

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WHEREAS, it is reasonable and appropriate under the circumstances to extend by
approximately 90 days the trial date and all related discovery deadlines in this matter.
THEREFORE, IT IS HEREBY STIPULATED by and between the parties through

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their respective attorneys of record that good cause exists to vacate the dates ordered in the

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March 18, 2013 Case Management Scheduling Order and to set the following dates, subject to

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the Court’s availability:

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•

Fact Discovery Cut-Off: November 22, 2013;

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•

Expert Witness Disclosure and Reports: January 10, 2014;

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•

Rebuttal Expert Reports: February 10, 2014;

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•

Expert Discovery Cut-Off: March 10, 2014;

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•

Last Date to Hear Dispositive Motions: May 22, 2014;

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•

Trial Date: June 30, 2014.

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Good cause exists for the modification to the schedule because discovery has not yet

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ATTORNEYS AT LAW
SAN FRANCISCO

commenced in this case and the remaining defendants are still undetermined.
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STIPULATION AND [PROPOSED] ORDER TO
EXTEND CASE MANAGEMENT DEADLINES
CASE NO. C 10-03610 RMW

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[PROPOSED] ORDER
Pursuant to stipulation, and good cause existing therefore, it is ordered that that dates

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ordered in the March 18, 2013 Case Management Scheduling Order are hereby VACATED in

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lieu of the following dates:

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•

Fact Discovery Cut-Off: November 22, 2013;

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•

Expert Witness Disclosure and Reports: January 10, 2014;

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•

Rebuttal Expert Reports: February 10, 2014;

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Expert Discovery Cut-Off: March 10, 2014;

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Last Date to Hear Dispositive Motions: May 22, 2014, and;

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Trial Date: June 30, 2014.

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IT IS SO ORDERED.

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Dated: ___________________

_______________________________
Hon. Ronald M. Whyte
United States District Court Judge

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ATTORNEYS AT LAW
SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER TO
EXTEND CASE MANAGEMENT DEADLINES
CASE NO. C 10-03610 RMW