Armstrong v. The City of San Jose et al
Filing
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***SEE ADDITIONAL ATTACHMENT FOR CORRECT/SIGNED ORDER****ORDER GRANTING 40 STIPULATION TO EXTEND DEADLINES. Signed by Judge Edward J. Davila on 6/23/2017. (ejdlc2S, COURT STAFF) (Filed on 6/23/2017) (Additional attachment(s) added on 6/23/2017: # 1 CORRECTED ORDER) (amkS, COURT STAFF). Modified text on 6/23/2017 (amkS, COURT STAFF).
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RICHARD DOYLE, City Attorney (88625)
NORA FRIMANN, Assistant City Attorney (93249)
ARDELL JOHNSON, Chief Deputy City Attorney (95340)
KENDRA MCGEE-DAVIES, Senior Deputy City Attorney (260459)
Office of the City Attorney
200 East Santa Clara Street, 16th Floor
San José, California 95113-1905
Telephone Number: (408) 535-1900
Facsimile Number: (408) 998-3131
E-Mail Address: cao.main@sanjoseca.gov
Attorneys for CITY OF SAN JOSE
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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DAVID ARMSTRONG,
Plaintiff(s),
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v.
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CITY OF SAN JOSE; SAN JOSE POLICE
OFFICER ALEXANDER KELLER; SAN
JOSE POLICE OFFICER BALDWIN; SAN
JOSE POLICE OFFICER ZARATE; AND
SAN JOSE POLICE OFFICER
BORTOLOTTI, and DOES, inclusive,
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Case Number: 16-cv-02938-EJD
STIPULATED REQUEST FOR AN
ORDER EXTENDING DISCOVERY
DEADLINES AND [PROPOSED]
ORDER (Local Rule 6-2)
as modified below
Defendant(s).
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Plaintiff David Armstrong and Defendants City of San Jose, Officer Alexander
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Keller, Officer Glenn Baldwin, Officer Christine Zarate, and Sergeant Damian Bortolotti
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(collectively the “City”) respectfully submit this stipulation as follows:
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WHEREAS, the Court approved the following discovery deadlines on March 24,
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2017;
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///
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///
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STIPULATION FOR EXTENDING DISCOVERY DEADLINES AND
[PROPOSED] ORDER
Case Number: 16-cv-02938-EJD
1427912
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Event
Deadlines
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Fact Discovery Cutoff
July 12, 2017
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Designation of Opening Expert with Reports
September 8, 2017
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Designation of Opening Experts with Reports
October 6, 2017
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Expert Discovery Cutoff
September 25, 2017
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Deadline for Filing Discovery Motions
See Civil Local Rule 37-3
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Deadline for Filing Dispositive Motions
July 19, 2017
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Hearing on Anticipated Dispositive Motions
August 21, 2017
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WHEREAS, the Court referred this matter for Early Neutral Evaluation on March 1,
2017 to be completed on or before May 30, 2017;
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WHEREAS, the parties have not been able to complete the ENE due to the
availability of the parties and neutral evaluator;
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WHEREAS, the Court extended the deadline to complete the ENE to August 30,
2017;
WHEREAS, the Parties desire to meaningfully engage in settlement negotiations
and avoid costs associated with discovery, as much as possible;
WHEREAS, the Parties will not be able to complete the necessary depositions in
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light of pre-planned vacations of various witnesses before the fact discovery cutoff
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deadline of July 12, 2017;
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NOW, THEREFORE, THE PARTIES STIPULATE AS FOLLOWS:
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1.
The discovery deadlines shall be extended as follows:
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Deadlines
Event
Fact Discovery Cutoff
August 14, 2017
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Designation of Opening Expert with Reports
September 8, 2017 (unchanged)
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Designation of Opening Experts with Reports
October 6, 2017 (unchanged)
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Expert Discovery Cutoff
September 25, 2017 (unchanged)
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STIPULATION FOR EXTENDING DISCOVERY DEADLINES AND
[PROPOSED] ORDER
Case Number: 16-cv-02938-EJD
1427912
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Deadline for Filing Discovery Motions
See Civil Local Rule 37-3
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Deadline for Filing Dispositive Motions
August 23, 2017
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Hearing on Anticipated Dispositive Motions
September 25, 2017
October 5, 2017
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2.
All other deadlines established by the Court shall remain the same.
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Respectfully submitted,
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RICHARD DOYLE, City Attorney
Dated: June 21, 2017
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By: /Kendra McGee-Davies/__
KENDRA MCGEE-DAVIES
Deputy City Attorney
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Attorneys for CITY OF SAN JOSE; SAN
JOSE POLICE OFFICER ALEXANDER
KELLER; SAN JOSE POLICE OFFICER
BALDWIN; SAN JOSE POLICE OFFICER
ZARATE; AND SAN JOSE POLICE
OFFICER BORTOLOTTI
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STEVEN HORNER
Dated: June 21, 2017
By: /Stephen Horner/_____
STEPHEN HORNER
Attorney for PLAINTIFF DAVID
ARMSTRONG
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STIPULATION FOR EXTENDING DISCOVERY DEADLINES AND
[PROPOSED] ORDER
Case Number: 16-cv-02938-EJD
1427912
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PROPOSED ORDER
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Pursuant to the foregoing stipulation of the Parties and good cause appearing
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therefore, the Court orders as follows:
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Event
Deadlines
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Fact Discovery Cutoff
August 14, 2017
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Designation of Opening Expert with Reports
September 8, 2017 (unchanged)
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Designation of Opening Experts with Reports
October 6, 2017 (unchanged)
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Expert Discovery Cutoff
September 25, 2017 (unchanged)
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Deadline for Filing Discovery Motions
See Civil Local Rule 37-3
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Deadline for Filing Dispositive Motions
August 23, 2017
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Hearing on Anticipated Dispositive Motions
September 25, 2017
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IT IS SO ORDERED.
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Dated: ________________
__________________________________
HON. EDWARD J. DAVILA
UNITED STATES DISTRICT COURT
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STIPULATION FOR EXTENDING DISCOVERY DEADLINES AND
[PROPOSED] ORDER
Case Number: 16-cv-02938-EJD
1427912
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