Teresi Investments v. City of Mountain View

Filing 32

STIPULATION AND ORDER Extending Fact and Expert Discovery Deadlines re 31 Stipulation. Fact Discovery Cutoff 5/18/2012. Expert Discovery cutoff 7/27/2012. Preliminary Pretrial Conference statement due 4/20/2012. Preliminary Pretrial Conference set for 4/20/2012 11:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J. Davila. Signed by Judge Edward J. Davila on 1/9/2012. (ecg, COURT STAFF) (Filed on 1/9/2012)

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S 6 7 8 9 10 11 12 13 14 15 16 ER R NIA Davila FO w a rd J . LI d J u d ge E A H 5 RT 4 D RDERE IS SO O FIED IT DI AS MO NO 3 UNIT ED 2 NORMAN EDWARD MATTEONI (SBN: 34724) GERALD HOULIHAN (SBN: 214254) MATTEONJ O'LAUGHLIN HECHTMAN 848 The Alameda San Jose, CA 95126 Telephone: 408-293-4300 Facsimile: 408-293-4005 RT U O 1 ISTRIC ES D TC AT T N F D IS T IC T O R C Attorneys for Plaintiff TERESI INVESTMENTS, a California Limited Partnership LOUIS A. LEONE, ESQ. (SBN: 099874) JENNIFER N. LOGUE, ESQ. (SBN: 241910) STUBBS & LEONE A Professional Corporation 2175 N. California Blvd., Suite 900 Walnut Creek, CA 94596 Telephone: (925) 974-8600 Facsimile: (925) 97 4-8601 JANNIE QUINN, ESQ. (SBN: 137588) Office of the City Attorney 500 Castro Street Mountain View, CA 94039-7540 Telephone: (650) 903-6303 Facsimile: (650) 967-4215 17 18 Attorneys for Defendant CITY OF MOUNTAIN VIEW 19 UNITED STATES DISTRICT COURT 20 NORTHERN DISTRICT OF CALIFORNIA 21 SAN JOSE DIVISION 22 23 TERESI INVESTMENTS, a California Limited Partnership Plaintiff, 24 25 26 27 28 vs. Case No.: C10-04714 EJD STIPULATION, JOINT REQUEST AND [PROPOSED] ORDER EXTENDING FACT AND EXPERT DISCOVERY DEADLINES CITY OF MOUNTAIN VIEW, a Municipal Corporation, and DOES 1-10, inclusive Defendants. STIPULATION, JOINT REQUEST AND [PROPOSED} ORDER EXTENDING FACT AND EXPERT DISCOVERY DEADLINES WHEREAS the above-captioned matter was removed from the Superior Court of 2 3 the State of California, County of Santa Clara to the United States District Court for the 4 Northern District of California, San Jose Division on October 19, 201 0; WHEREAS on March 9, 2011, Chief Judge James Ware issued a scheduling 5 6 order setting the close of all discovery in this case on March 16, 2012 and directing the 7 parties to exchange and lodge with the Court all expert witness information and expert 8 reports by January 13, 2012, 63 days before the close of discovery; WHEREAS Plaintiff filed by stipulation a first amended complaint on June 7, 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 2011; WHEREAS Defendant City of Mountain View filed an Answer to Plaintiff's First Amended Complaint and a Counterclaim on July 12, 2011; WHEREAS the parties have made initial disclosures pursuant to Federal Rule of Civil Procedure 26, exchanged written discovery requests and jointly have produced more than 10,000 pages of documents in response to the respective written discovery requests; WHEREAS each side continues to review the multitude of documents produced in this case; WHEREAS the parties have retained experts but have been unable to provide their respective expert witnesses with all of the information necessary for their reports given that document review continues and the parties are still working on scheduling depositions; WHEREAS the parties reserve the right to retain liability experts but are in agreement that at this time it appears the expert testimony primarily will be on the issue of damages; WHEREAS Defendant City of Mountain View is currently drafting a motion for summary judgment as to all of Plaintiff's causes of action; 28 STIPULATION, JOINT REQUEST AND [PROPOSED] ORDER EXTENDING FACT AND EXPERT DISCOVERY DEADLINES 2 WH EREAS Defendant City of Mountain View's motion for summary judgment will 2 be filed within three weeks; 3 IT IS HEREBY STIPULATED and respectfully requested by all parties to this 4 action that the fact discovery deadline be extended an additional 63 days to May 18, 5 2012, that the expert disclosure deadline be extended to June 18, 2012 and that the 6 expert discovery deadline be extended to July 27, 2012. 7 8 Dated: January .1_, 2012 MATTEONI, O'LAUGHLIN & HECHTMAN 9 10 11 N A E ARD MATTEONI, ESQ. GERALD HOULIHAN, ESQ. Attorneys for Plaintiff TERES I INVESTMENTS 12 13 14 15 Dated: January ~ยท 2012 STUBBS & LEONE 16 LO IS . LEONE, ESQ. JENER::OGUE, ESQ. Attorneys for Defendant CITY OF MOUNTAIN VIEW 17 18 19 20 21 22 23 24 25 Pursuant to the parties stipulation, IT IS ORDERED THAT: 1. Fact Discovery will close May 18, 2012; 2. Expert Disclosure shall be made no later than June 18, 2012; and 3. Expert Discovery will close July 27, 2012. 4. The Preliminary Pretrial Conference scheduled for February 17, 2012, is CONTINUED to April 20, 2012, _11:00 ,a.m. The parties shall file a Joint Preliminary Pretrial Conference Statement no Dated: _ at _ _ 2012 later than April 10, 2012. 26 27 DATED: January 9, 2012 EDWARD J. DAVILA United States District Judge 28 STIPULATION, JOINT REQUEST AND [PROPOSED] ORDER EXTENDING FACT AND EXPERT DISCOVERY DEADLINES 3

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