Filed: Jan. 02, 2015
Latest Update: Jan. 02, 2015
Summary: STIPULATION AND REQUEST FOR ORDER CHANGING TIME; [PROPOSED] ORDER; DECLARATION OF LORI COSTANZO IN SUPPORT EDWARD J. DAVILA, District Judge. Plaintiff and Defendants, by and through their respective counsels, stipulate and request that the court change the times in the Court's Case Management Order (Docket No. 20) filed on August 8, 2014, as described below. The parties have not requested a modification of the original Case Management Order before. Pursuant to Local Rule 6-2, this request is
Summary: STIPULATION AND REQUEST FOR ORDER CHANGING TIME; [PROPOSED] ORDER; DECLARATION OF LORI COSTANZO IN SUPPORT EDWARD J. DAVILA, District Judge. Plaintiff and Defendants, by and through their respective counsels, stipulate and request that the court change the times in the Court's Case Management Order (Docket No. 20) filed on August 8, 2014, as described below. The parties have not requested a modification of the original Case Management Order before. Pursuant to Local Rule 6-2, this request is a..
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STIPULATION AND REQUEST FOR ORDER CHANGING TIME; [PROPOSED] ORDER; DECLARATION OF LORI COSTANZO IN SUPPORT
EDWARD J. DAVILA, District Judge.
Plaintiff and Defendants, by and through their respective counsels, stipulate and request that the court change the times in the Court's Case Management Order (Docket No. 20) filed on August 8, 2014, as described below. The parties have not requested a modification of the original Case Management Order before.
Pursuant to Local Rule 6-2, this request is accompanied by the declaration of attorney Lori Costanzo, counsel for Plaintiff. As set forth more specifically in the declaration, in light of the Plaintiff just having filed her Second Amended Complaint on December 26, 2014, Defendants not yet having filed an Answer or other responsive pleading, Plaintiff's deposition set for January 5, 2015, as well as the need for Plaintiff to file a motion to obtain personnel files of each officer before taking each officer's deposition, the parties wish to have more time to complete discovery.
Accordingly, Plaintiff — in agreement with Defendants — is requesting a six month continuance of the respective case management dates as follows:
Current Date Proposed Date
Fact Discovery Cut-Off February 6, 2015 August 6, 2015
Designation of Opening March 6, 2015 September 4, 2015
Experts w/Reports
Designation of Rebuttal March 20, 2015 September 21, 2015
Experts w/Reports
Expert Discovery Cutoff March 27, 2015 September 28, 2015
Deadline(s) for Filing Discovery Motions See Civil Local Rule 37-3
Last Day for Dispositive Motion Hearing April 3, 2015 October 5, 2015
Preliminary Pretrial Conference January 16, 2015 Court's convenience
Joint Preliminary PreTrial Conference Stmt January 6, 2015 July 6, 2015
Trial Not yet set
IT IS SO STIPULATED.
I hereby attest that I have on file the holograph signature for the signature indicated by a "conformed" signature (/s/) within the e-filed document.
ORDER
The Court has considered the Stipulation and request by the parties to change the time of the set forth in the court's Case Management Order (Docket No. 20). The Court having determined that the request is properly supported, hereby makes the following Order:
The Case Management Order is modified to reflect the following:
Fact Discovery Cut-Off August 6, 2015
Designation of Opening Experts with Reports September 4, 2015
Designation of Rebuttal Experts with Reports September 21, 2015
Expert Discovery Cutoff September 28, 2015
Deadline(s) for Filing Discovery Motions See Civil Local Rules
Hearing on Anticipated Dispositive 9:00 a.m. on
Motions October 5, 2015
Trial Setting Conference 11:00 a.m. on
July 16, 2015
Joint Joint Setting Conference Statement July 6, 2015
(see Section (C)(2) of Standing Order for
Civil Case)
PURSUANT TO STIPULATION, IT IS SO ORDERED.
