The opinion of the court was delivered by: Honorable Jeffrey S. White United States District Court Judge
JOHN L. BURRIS, Esq./ State Bar # 69888 LAW OFFICES OF JOHN L. BURRIS 7677 Oakport Street, Suite 1120 Oakland, CA 94621 Telephone: (510) 839-5200 Facsimile: (510) 839-3882 E-Mail: firstname.lastname@example.org GAYLA B. LIBET, Esq./ State Bar # 109173 LAW OFFICES OF GAYLA B. LIBET 486 41st Street, Suite 3 Oakland, CA 94609 Telephone and Facsimile: (510) 420-0324 E-Mail: email@example.com Attorneys for Plaintiff ARLENE M. ROSEN/ State Bar # 100160 Senior Deputy City Attorney OAKLAND CITY ATTORNEY'S OFFICE One Frank Ogawa Plaza, Sixth Floor Oakland, CA 94612 Telephone: (510) 238-6392 Facsimile: (510) 238-6500 E-Mail: Arosen@oaklandcityattorney.org
STIPULATION AND PROPOSED ORDER FOR EXTENSION OF TIME TO DISCLOSE EXPERTS AND EXPERT REPORTS; AND TO EXTEND TIME TO COMPLETE EXPERT DISCOVERY
All parties to this action stipulate and agree, by and through their respective counsel, as follows:
1. That the following good cause exists for extending the time for disclosure of expert witnesses and expert reports; for extending the time for expert discovery to be completed; and for extending the cut-off date for hearing of dispositive motions;
2. Judge Larson was originally the Magistrate Judge with whom there was to be a Settlement Conference in this case. It was scheduled for on August 27, 2011. Since the retirement of Judge Larson from this Court, Magistrate Judge Jacqueline Scott Corley has been assigned as the Magistrate Judge who will schedule and preside at Settlement Conference in this case. The date of September 2, 2011 has been selected for the Settlement Conference;
3. By extending the time for disclosure of expert witnesses and expert reports; and extending the time for expert discovery to be completed, the parties may not have to bear the cost of retaining experts, should the case settle prior to the requested new extended dates for expert disclosure and discovery;
4. As set forth in the Court's Order, dated 5-25-11, the Pretrial Conference is scheduled for 11-14-11 at 2:00 p.m., and the scheduled date for Trial is 12-5-11 at 8:00 a.m.. Therefore, the parties' request for extension of deadlines should not interfere with the presently scheduled pretrial and trial dates set by the Court; and,
5. For all the good cause reasons stated above, the parties respectfully request, that the following dates set forth in the Court's Order, dated 5-25-11, be extended, as follows:
(A) That the date for disclosure of expert witnesses and expert reports be extended from August 3, 2011 to October 12, 2011;
(B) That the cut-off date for completion of expert discovery be extended from August 17, 2011 to November 3, 2011; and,
(C ) That the last date to hear dispositive motions be extended from September 9, 2011 at 9:00 a.m. to October 20, 2011.
PURSUANT TO STIPULATION, IT IS ...