Free Stipulation - District Court of California - California

Case 5:07-cv-02523-RS

Document 36

Filed 08/08/2008

Page 1 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

KATE WELLS, SBN 107051 2600 Fresno Street Santa Cruz, California 95062 Telephone: (831) 479-4475 Facsimile: (831) 479-4476 Email Address: [email protected] DAVID K. MEYBERG, SBN 236636 223 Walnut Avenue, Suite D Santa Cruz, California 95060 Telephone: (831) 469-4509 Facsimile: (831) 469-4509 Email Address: [email protected] Attorneys for Plaintiffs, DYLAN GREINER, individually and dba SANTA CRUZ SURF SCHOOL, ALIJAH K. CROWELL, DAVID M. AVARY George J. Kovacevich, SBN 48125 Barbara H. Choi, SBN 156088 ATCHISON, BARISONE, CONDOTTI & KOVACEVICH A Professional Corporation 333 Church Street Santa Cruz, California 95060 Telephone: 831-423-8383 Facsimile: 831-423-9401 Email: [email protected] Attorneys for Defendants, CITY OF SANTA CRUZ, JOHN ALEXIOU, DANATEE SHOEMAKER and CAROL SCURICH. UNITED STATES DISTRICT COURT

17 NORTHERN DISTRICT OF CALIFORNIA 18 E-FILING CASE 19 20 21 22 23 24 25 26 27 Defendants. 28 DYLAN GREINER, individually and dba SANTA CRUZ SURF SCHOOL; ALIJAH K. CROWELL; DAVID M. AVARY; Plaintiffs, vs. CITY OF SANTA CRUZ; OFFICER JOHN ALEXIOU; DANETTEE SHOEMAKER; CAROL SCURICH; JOHN BARISONE; ED GUZMAN, individually and dba CLUB ED; and DOES ONE THROUGH TEN, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. C07 02523 RS STIPULATION TO CONTINUE DATES FOR CMC AND OTHER PRE-TRIAL DEADLINES REQUEST FOR ORDER

STIPULATION TO CONTINUE DATE FOR CMC AND OTHER DEADLINES Greiner,et al. v. City of Santa Cruz, et al. Case No. C07-2523-RS

1

Case 5:07-cv-02523-RS

Document 36

Filed 08/08/2008

Page 2 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

The parties, Defendants CITY OF SANTA CRUZ, OFFICER JOHN ALEXIOU, DANNETTEE SHOEMAKER, and CAROL SCURICH, and Plaintiffs, DYLAN GREINER, individually and dba SANTA CRUZ SURF SCHOOL, ALIJAH K. CROWELL, DAVID M. AVARY, by and through their attorneys of record, hereby agree and stipulate to continue the dates for the Case Management Conference and other pretrial dates as follows: 1. The date for the Case Management Conference is continued from September 24, 2008, to December 10, 2008. An updated joint case management conference statement shall be filed no later than December 3, 2008; 2. The date for the completion of all non-expert discovery is continued from September 30, 2008, to December 3, 2008; 3. The last date for plaintiffs to disclose expert testimony and reports is continued from September 15, 2008 to November 26, 2008; 4. The last date for defendants to disclose expert testimony and reports is continued from September 30, 2008 to December 3, 2008; 5. The deadline for all discovery of expert witnesses is continued from October 24, 2008, to January 4, 2008; 6. The deadline for hearing of all pretrial motions is continued from January 28, 2009, to March 28, 2009. All other dates, including the date for pretrial statements (June 15, 2009), pretrial conference (June 24, 2009) and trial (July 6, 2009) will remain unchanged. Good cause exists for the requested continuances in that the parties have had scheduling conflicts that have interfered with their ability to meet the deadlines as they were previously set by the court. The parties have been continuing discussions in good faith and need the additional time to complete discovery in order to facilitate any possibility of settling the case short of trial. Additionally, the requested continuance of the dates and deadlines will not interfere with the trial date as scheduled. /// ///
STIPULATION TO CONTINUE DATE FOR CMC AND OTHER DEADLINES Greiner,et al. v. City of Santa Cruz, et al. Case No. C07-2523-RS

2

Case 5:07-cv-02523-RS

Document 36

Filed 08/08/2008

Page 3 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

IT IS SO STIPULATED:

LAW OFFICES OF KATE WELLS

Dated: August 8, 2008

By:

/s/ KATE WELLS Attorney for Plaintiffs

ATCHISON, BARISONE, CONDOTTI & KOVACEVICH

Dated: August 8, 2008

By:

/s/ BARBARA CHOI, Attorneys for Defendants, CITY OF SANTA CRUZ, OFFICER JOHN ALEXIOU, DANETTEE SHOEMAKER, and CAROL SCURICH

ORDER (BY STIPULATION) GOOD CAUSE APPEARING THEREFOR it is hereby ordered that 1. The date for the Case Management Conference is continued from September 24, 2008, to December 10, 2008. An updated joint case management conference statement shall be filed no later than December 3, 2008; 2. The date for the completion of all non-expert discovery is continued from September 30, 2008, to December 3, 2008; 3. The last date for plaintiffs to disclose expert testimony and reports is continued from September 15, 2008, to November 26, 2008;
STIPULATION TO CONTINUE DATE FOR CMC AND OTHER DEADLINES Greiner,et al. v. City of Santa Cruz, et al. Case No. C07-2523-RS

3

Case 5:07-cv-02523-RS

Document 36

Filed 08/08/2008

Page 4 of 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated:

4. The last date for defendants to disclose expert testimony and reports is continued from September 30, 2008 to December 3, 2008; 5. The deadline for all discovery of expert witnesses is continued from October 24, 2008, to January 4, 2008; 6. The deadline for hearing of all pretrial motions is continued from January 28, 2009, to March 28, 2009. All other dates will remain the same as previously scheduled

THE HONORABLE RICHARD SEEBORG UNITED STATES MAGISTRATE JUDGE

STIPULATION TO CONTINUE DATE FOR CMC AND OTHER DEADLINES Greiner,et al. v. City of Santa Cruz, et al. Case No. C07-2523-RS

4