UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
February 4, 2011
POLICE DEPARTMENT; AND HEATHER FONG, INDIVIDUALLY AND IN HER OFFICIAL
CAPACITY AS CHIEF OF THE SAN FRANCISCO POLICE DEPARTMENT,
The opinion of the court was delivered by: The Honorable Elizabeth D. Laporte
STIPULATED REQUEST FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS' MOTION FOR PROTECTIVE THE CITY AND COUNTY OF SAN ORDER AND PLAINTIFF'S 2ND MOTION TO FRANCISCO; the SAN FRANCISCO COMPEL and [PROPOSED] ORDER 17
[Civ. L.R. 6-2; 7-12]
Hearing Date: March 15, 2011 Time: 9:00 A.M. Place: Court E, 15th Floor,SF Trial Date: None Set
Pursuant to Civil Local Rules 6-2 and 7-12, Defendants and Plaintiff submit the following stipulation and request for an Order shortening time to hear Defendants' Motion for Protective Order, 25 filed February 4, 2011 and Plaintiff's 2nd Motion to Compel, also filed February 4, 2011. In the 26 alternative, Defendants request that the court stay discovery related to the deposition of the City and 27
County of San Francisco pending the outcome of its Motion for Protective Order.
Joint Stipulation for Order Shortening Time 1
and Plaintiff's Motion for Attorney's Fees and Costs to March 8,
2011 at 9:00 a.m. in Courtroom E,
On this same date, Defendant City received an amended deposition
notice from plaintiff, setting a Rule
Defendant served objections to plaintiff's deposition notice on
February 1, 2011. Plaintiff
responded to defendant's request to meet and confer on February 3
and the parties were unable to come 8 to any agreement. Defendant is
not only unavailable for deposition on February 16, but also seeks a 9
protective order regarding the Rule 30(b)(6) deposition notice, as
well as certain categories of 10 information sought in discovery by
plaintiff and subject of plaintiff's Motion to Compel set for hearing
During its meet and confer, Plaintiff informed Defendant of his desire
to file a 2nd Motion to
Compel. Defendants agreed that if the motion was filed by February 4,
it would stipulate to it being 14 heard on the same shortened schedule
as the City's Motion for Protective Order.
Defendant in a second meet and confer phone conference held the
morning of February 4, 2011 that he would be filing his second
Motion to Compel today. For sake of economy and efficiency, and due to
overlapping issues in both Plaintiff's two Motions to Compel and
Defendant's Motion for Protective for both motions would save opposing counsel an additional trip to
San Francisco for an additional hearing.
Order, the parties respectfully request that their motions filed
February 4, 2011 be heard on shortened 20 time, and on the same date
set for plaintiff's 1st Motion to Compel:
March 8, 2011. In addition, the 21 discovery cut off in both cases is
set for March 18, 2011.
Administrative Motion for Relief and defendant's request for a shortened briefing schedule. Both 27 parties agree and stipulate to the proposed shortened schedule.
On January 31, 2011 the court re-set the hearing schedule on Plaintiff's 1st Motion to Compel 15th Floor, United States District Court, 450 Golden Gate Avenue, San Francisco, California, 94102. 30(b)(6) deposition for February 16, 2011. 6
March 8, 2011. 12
Defendant filed its Motion for Protective Order today, February 4, 2011. Plaintiff informed Moreover, plaintiff's counsel is located in Los Angeles and a consolidation of the hearing dates The parties met and conferred on February 3, 2011and February 4, 2011 regarding this Motion for Protective Order and Plaintiff's 2nd Motion to Compel filed February 4, 2011: Hearing on Opposition briefs due February 16, 2011; and Reply briefs due February 23, 2011.
The parties propose the following shortened hearing date and briefing schedule for the City's Defendant's Motion for Protective Order and Plaintiff's 2nd Motion to Compel March 8, 2011; A stipulation and proposed order is included below.
DENNIS J. HERRERA City Attorney ELIZABETH S. SALVESON Chief Labor Attorney JONATHAN C. ROLNICK By: /s/ Lauren M. Monson LAUREN M. MONSON Attorneys for Defendant(s) CITY AND COUNTY OF SAN FRANCISCO, et al.
IT IS STIPULATED BY THE PARTIES AS FOLLOWS:
Defendant's Motion for Protective Order and Plaintiff's 2nd Motion to Compel, filed February 4, 2011, shall be heard on shortened time. Defendant's Motion for Protective Order and Plaintiff's 2nd
Motion to Compel will be heard on March 8, 2011 at 9:00 a.m. in Courtroom E, 15th Floor, United States District Court, 450 Golden Gate Avenue, San Francisco, California, 94102. Opposition briefs 6 are due February 16, 2011 and Reply briefs are due February 23, 2011. 7 8
Dated: February 4, 2011
DENNIS J. HERRERA City Attorney ELIZABETH S. SALVESON Chief Labor Attorney By: /s/ Lauren M. Monson LAUREN M. MONSON Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO, et al.
Dated: February 4, 2011
By: /s/ Thomas K. Bourke Thomas K. Bourke
Attorney for Plaintiff FREDERICK SCHIFF
PURSUANT TO STIPULATION, AND AGREEMENT OF THE COURT, IT IS SO
ES DIST T RI A CT Dated: February 2011 15, C S T O E D U R
T ________ T N IT IS ORDERED
U A I N N Elizabeth D. Laporte R O Judge O R I T H A F L
CASE NO. C08-4627PJH N DIS O
Joint Stipulation for Order Shortening Time E
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