Doe v. Washington Township Healthcare District et al

Filing 40

STIPULATION AND ORDER re 39 Stipulation and [Proposed] Order to Extend Discovery (Second Request) filed by Jane Doe. Signed by Magistrate Judge Howard R. Lloyd on 12/20/2013. (hrllc1, COURT STAFF) (Filed on 12/20/2013)

*E-Filed: December 20, 2013*
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Jason O. Runckel, Esq.(California SBN: 198361)
Thomas M. O'Connor, Esq,(California SBN: 172236)
William D. O'Malley, Esq.(California SBN; 129605)
O'CONNOR,RUNCKEL & O'MALLEY LLP
1277 T~•eat Boulevard, Suite 810
Walnut Creek, CA 94597
Telephone:[phone]
Facsimile:[phone]
Attorneys for Plaintiff, Jane Doe

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iN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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Case No, CV 13-00745 HRL

JANE DOE,

STIPULATION AND [PROPOSED)
ORDER TO EXTEND DISCOVERY
(SECOND REQUEST)

Plaintiff,
v.

WASHINGTiJN TOWNSHIP HEALTHCARE
DISTRICT, WASHINGTON HOSPITAL,JON
QUTANZON and ROES 1 to 25,inclusive,

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Defendants.

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STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY
(SECOND REQUEST)

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STIPULATION

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Pursuant to LR 6.1(b) and 6.2, the patties, by and through their respective attorneys of

k record, stipulate and agree that the existing discovery deadlines be extended 30 days in accordance

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with the information set forth below.
Discovery Completed

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I.

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The parties have completed the following discovery:

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-

The parties have made initial disclosures pursuant to Fed. R. Civ. Proc. 26

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STIPULATION AND [PROPOSED)ORDER TO EXTEND DISCOVERY(SCCOND EtGQUEST)

The parties have served and responded to written discovery.

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The parties leave subpoenaed various custodians of records and have received responses
to those subpoenas,

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-

The following depositions have been taken:

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Jane Doe {Plaintiff

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Michael Platzbecke~•

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-

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Joanne Furlong
Hai Dang

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-

Tliao Moscheiti

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Bryant Welch

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-

Kadeer Halimi, M.D.

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-

Gw•preet Singh

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Fremont Police Officer, Ricardo Cortes

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Fremont Police Offtcer (Ret,} Tex'esa Mactniez

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Belt wescotc

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Joey Schreifer

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Ciu•istopher Sato-Perry, Psy.D.

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Kaveri Patel, M.D.

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Remaining Discovery

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The following deposifioiis remain;

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Jon Quianzon — cux7•ently incarcerated and awaiting sentencing.

Supplemental written discovery as needed
The parties may need to issue additional subpoenas

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STIPULATION AND [PROPOSED]OC2DER TO EXTEND DISCOVERY(SECOND It~QiJ~ST)
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Any additional discovery the panties deem necessary within the scope of permissible
discovery under the Federal Rules of Civil Procedure.

III.

Reasons Discovery Cannot Be Completed

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The deposition of Jon Quianzon, currently housed at San Quentin Prison, Inmate No.
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AR3943, was originally scheduled to beheld on December 19, 2013 at San Quentin Prison.

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Plaintiffls counsel spoke with Mr, Quianzon's criminal attorney, Frank Leidman, who informed

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him that Mr. Quianzon would not respond to any questions and would invoke leis right under the

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Fifth Amendment. He z~equested that said deposition be postponed until after Mr. Quianzon is

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sentenced and the criminal inattei• is resolved. Mr. Quianzon is cu~•rently set for sentenci~~g on the
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criminal case on December 23, 2013 in Alameda County.
Additional discovery may be required following the completion ofthe Mr. Quianzon's

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deposition and current discovery deadline does not allow enough time within which to complete it.

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Accordingly the parties stipulate and agree to continue discovery deadlines for 30 days to allow

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J enough time to conduce any potential supplemental discovery.

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IV.

Proposed Discave~y Schedule

The panties stipulate and agree to the following 30 day extension of the existing Discovery

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20 ~ and Expert Witness Cutoff dates:

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Current Dafe

Proposed Date

December 2, 2013

February 3,2014

Designation of Experts with Reports

February 3, 2014

March 3,2014

Designation of Rebuttal Experts with
Reports

March 4, 2014

Apri14,2014

Expert Discovery Cutoff

Apri14,2014

May 5,2014

~ Fact Discovery Cutoff
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STIPULATI0~3 AND [PROPOSED]ORDER TO EXTEND DISCOVCRY (S~COI~ID REQUES'[)
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Final Pretrial Conference

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~, Juiy Trial

June 19, 2014 at 1:30 pm

June 19, 2014 at 1:30 pm
TBD

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Dated: December 18, 2013

O'CONNO

RUNCKEL & O'MALLEY

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J s O. unckel
ttorney for Plaintiff, Jane Doe

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Dated: December '~,2013

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GALLOWAY,LUCCHESE,EVERSON &
PICCHI

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Martin J. Everson
Attorney for Defendant Washington Township
Healthcare District

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QRDER
Pursuant to Stipulation it is so ORDERED that the Fact Discovery Cutoff and Expert

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Witness Disclosure/Discovery is hereby extended. The new dates are as follows:

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Fact Discovery Cutoff

Febivai•y 3,2014

Designation of Experts with Reports

March 3, 2014

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Designation of Rebuttal Experts with
Reports

April 4, 20i4

Expert Discovery Cutoff

May S,2014

Final Pret►~ial Conference

June 19, 2014 at 1:30 pm

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Jut~y Trial

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STIPULATION AND[PROPOSED] ORDER TO EXTEND DISCOVERY(SECOND REQITEST)
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,
All other scheduled dates remain in place, including the last day for hearing dispositive motions

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on May 13, 2014.

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Dated; 12/20/13

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Howard R. Lloyd
United States Magish•ate Judge

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STIPULATIO~i AND [PROPOSED] ORDER TO EXTEND DISCOVERY(SECOND REQtJES"E')
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