Filed: Aug. 20, 2015
Latest Update: Aug. 20, 2015
Summary: STIPULATION AND (PROPOSED) ORDER TO AMEND CASE MANAGEMENT ORDER AS MODIFIED BY THE COURT VINCE CHHABRIA , District Judge . ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE, AND REQUEST THIS COURT TO ORDER, THAT the case management order be amended as follows: This is a complex civil rights case with 3 individual Defendants and 7 remaining Doe Defendants. The parties have exchanged initial disclosures, exchanged written discovery, and have subpoenaed records.
Summary: STIPULATION AND (PROPOSED) ORDER TO AMEND CASE MANAGEMENT ORDER AS MODIFIED BY THE COURT VINCE CHHABRIA , District Judge . ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE, AND REQUEST THIS COURT TO ORDER, THAT the case management order be amended as follows: This is a complex civil rights case with 3 individual Defendants and 7 remaining Doe Defendants. The parties have exchanged initial disclosures, exchanged written discovery, and have subpoenaed records. P..
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STIPULATION AND (PROPOSED) ORDER TO AMEND CASE MANAGEMENT ORDER AS MODIFIED BY THE COURT
VINCE CHHABRIA, District Judge.
ALL PARTIES, THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, HEREBY STIPULATE, AND REQUEST THIS COURT TO ORDER, THAT the case management order be amended as follows:
This is a complex civil rights case with 3 individual Defendants and 7 remaining Doe Defendants. The parties have exchanged initial disclosures, exchanged written discovery, and have subpoenaed records. Plaintiff has deposed the three individual Defendants. Defendants have completed Plaintiff's deposition. Depositions of additional eye and percipient witnesses and Rule 30(b)(6) witnesses have been noticed. Expert discovery is scheduled to open on August 31, 2015.
The parties have agreed that private mediation is appropriate at this stage of litigation, and if successful would minimize all parties' costs and attorneys' fees in this civil rights case. A private mediation is tentatively scheduled for September 11, 2015 with Hon. James Larson at JAMS.
Trial in this case is currently set for March 7, 2016. Expert reports are due August 31, 2015, rebuttal expert reports are due on September 21, 2015 and expert discovery will close on February 5, 2016. Fact discovery is set to close on September 30, 2015.
In order to maximize the chances of settlement, and of avoiding incurring otherwise unnecessary costs and fees, including those associated with expert disclosures and discovery, the parties stipulate to continue the current case management deadlines and trial date. This is the first request for extension of such deadlines.
Therefore, the parties respectfully request that this Court continue the current deadlines in this matter as follows:
Deadline Description Current Deadline/Date Proposed Modified
Deadline/Date
Completion of Fact Discovery September 30, 2015 December 9, 2015
Disclosure of Expert Witnesses' August 31, 2015 November 9, 2015
Identities and Reports
Disclosure of Rebuttal Expert September 21, 2015 December 9, 2015
Witnesses' Identity and Reports
Dispositive Motion Hearing December 3, 2015 January 28, 2016
Deadline
Settlement Conference December 9, 2015 February 9, 2016
Completion of Expert Discovery February 5, 2016 February 5, 2016
Pretrial Conference February 23, 2016 February 22, 2016
Jury Selection March 2, 2016
Trial March 7, 2016 March 7, 2016
* * See Judge Chhabria's Civil Standing Order, paragraph 9.
SO STIPULATED:
PURSUANT TO STIPULATION, IT IS SO ORDERED
