JOHN LUEBBERKE, City Attorney State Bar No. 164893 SHELLEY L. GREEN, Assistant City Attorney State Bar No. 161521 425 N. El Dorado Street, Second Floor Stockton, California 95202 Telephone: (209) 937-8333 Facsimile: (209) 937-8898 Attorneys for Defendants
STIPULATION OF COUNSEL TO EXTEND CASE DEADLINES AND DATES; ORDER THEREON
The parties in this matter have diligently attempted to complete discovery by the deadline of April 28, 2011; however, 21 have been unable to do so as a result of conflicting deadlines in 22 other cases and availability issues of deponents. Since all 23 depositions have yet to be completed, the parties are hesitant to 24 make expenditures for possibly unnecessary experts at this time 25 but are facing an expert discovery date of May 27, 2011. Trial 26 is currently scheduled for January 24, 2012. The parties are 27 requesting an extension of the discovery and expert disclosure 28 dates in an attempt to further analyze the merits of the case.
Additionally, the parties are requesting the Court set a settlement conference with a magistrate some time after the close of discovery. The following are the suggested changes to the calendar with the pretrial conference and trial date unchanged.
All parties agree the extension of these dates will allow them to adequately prosecute and defend the case. Therefore, IT IS HEREBY STIPULATED between the parties hereto, by and through their respective counsel that the current deadlines and dates in this matter be extended as follows:
1. Discovery Cutoff: From April 28 to July 1, 2011
2. Expert Disclosure: From May 27 to August 15, 2011
3. Dispositive Motions heard by: September 30, 2011
4. Pretrial Conference: October 26, 2011
5. Trial: January 24, 2012
In light of the foregoing stipulation of the parties, IT IS HEREBY ORDERED that the July 8, 2010 and Status (Pretrial Scheduling) Order and the December 8, 2010 order modifying that scheduling order are further modified as follows:*fn1
1. Motions to compel discovery must be heard not later June 1, 2011.
2. All discovery shall be completed by July 1, 2011.
3. On or before August 15, 2011, the parties shall designate in writing and file with the court, and serve upon all other parties, the names of all ...