Filed: Oct. 28, 2013
Latest Update: Oct. 28, 2013
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST) HOWARD R. LLOYD, Magistrate Judge. STIPULATION Pursuant to LR 6.1(b) and 6.2, the parties, by and through their respective attorneys of record, stipulate and agree that the existing discovery deadlines be extended 30 days in accordance with the information set forth below. I. Discovery Completed The parties have completed the following discovery: — The parties have made initial disclosures pursuant to Fed. R. Civ. Pro
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST) HOWARD R. LLOYD, Magistrate Judge. STIPULATION Pursuant to LR 6.1(b) and 6.2, the parties, by and through their respective attorneys of record, stipulate and agree that the existing discovery deadlines be extended 30 days in accordance with the information set forth below. I. Discovery Completed The parties have completed the following discovery: — The parties have made initial disclosures pursuant to Fed. R. Civ. Proc..
More
STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY (FIRST REQUEST)
HOWARD R. LLOYD, Magistrate Judge.
STIPULATION
Pursuant to LR 6.1(b) and 6.2, the parties, by and through their respective attorneys of record, stipulate and agree that the existing discovery deadlines be extended 30 days in accordance with the information set forth below.
I. Discovery Completed
The parties have completed the following discovery:
— The parties have made initial disclosures pursuant to Fed. R. Civ. Proc. 26
— The parties have served and responded to written discovery.
— The parties have subpoenaed various custodians of records and have received responses to those subpoenas.
— The following depositions have been taken:
— Jane Doe (Plaintiff)
— Michael Platzbecker
— Joanne Furlong
— Hai Dang
— Thao Moscheiti
II. Remaining Discovery
— The following depositions remain:
— Bryant Welch, currently scheduled for October 15, 2013
— Kadeer Halimi, M.D., currently scheduled for October 18, 2013
— Gurpreet Singh, currently scheduled for October 28, 2013
— Fremont Police Officer, Ricardo Cortes, currently scheduled for October 30, 2013
— Fremont Police Officer (Ret.) Teresa Martinez, cutTently scheduled for October 30, 2013
— Bill Wescott, currently scheduled for November 7, 2013
— Joey Schreifer, currently scheduled for November 7, 2013
— Christopher Sato-Perry, M.D., currently scheduled for October 31, 2013
— Kaveri Patel, M.D., currently scheduled for October 31, 2013
— Supplemental written discovery as needed following the last depositions in November
— The parties may need to issue additional subpoenas
— Any additional discovery the parties deem necessary within the scope of permissible discovery under the Federal Rules of Civil Procedure.
III. Reasons Discovery Cannot Be Completed
The depositions of Bryant Welch, Bill Wescott and Joey Schreifer were originally scheduled in early September and were continued until October 15, 2013 and November 7, 2013. An additional delay was incurred when Ms. Schreifer became unavailable due to a family medical emergency. Defendant's counsel has two trial scheduled in November and therefore he was unavailable for the majority of October due to expert witness depositions for said trials. The parties therefore have had to go into November to complete depositions.
Additional discovery may be required following the completion of the scheduled depositions and current discovery deadline does'not allow enough time within which to complete it. Accordingly the parties stipulate and agree to continue the non-expert discovery deadline 30 days to allow enough time to conduce any potential supplemental discovery.
IV. Proposed Discovery Schedule
The parties stipulate and agree to the following 30 day extension of the existing Fact Discovery Cutoff:
Current Date Proposed Date
Fact Discovery Cutoff December 2, 2013 January 2, 2014
Designation of Experts with Reports February 3, 2014 February 3, 2014
Designation of Rebuttal Experts with March 4, 2014 March 4, 2014
Reports
Expert Discovery Cutoff April 4, 2014 April 4, 2014
Final Pretrial Conference June 19, 2014 at 1:30 pm June 19, 2014 at 1:30pm
ORDER
Pursuant to Stipulation it is so ORDERED that the Fact Discovery Cutoff is hereby extended to January 2, 2014. All other scheduled dates remain in place.
