Ashley v. City and County of San Francisco et al
Filing
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ORDER GRANTING 43 STIPULATION Extending Deadlines for Mediation and for Amendments to the Complaint. Signed by Judge JEFFREY S. WHITE on 8/31/12. (jjoS, COURT STAFF) (Filed on 8/31/2012)
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DENNIS J. HERRERA, State Bar #139669
City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
PETER J. KEITH, State Bar #206482
LEILA K. MONGAN, State Bar #271287
Deputy City Attorney
Fox Plaza
1390 Market Street, Sixth Floor
San Francisco, California 94102-5408
Telephone:
(415) 554-3908 [Keith]
Telephone:
(415) 554-3915 [Mongan]
Facsimile:
(415) 554-3837
E-Mail:
peter.keith@sfgov.org
E-Mail:
leila.mongan@sfgov.org
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
JAMESON ASHLEY,
Plaintiff,
vs.
CITY AND COUNTY OF SAN
FRANCISCO, MICHAEL HENNESSEY,
individually and in his official capacity as
Sheriff of the San Francisco County Sheriff's
Department; and DOES 1 to 30,
Case No. CV-12-0045
JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING DEADLINES FOR
MEDIATION AND FOR AMENDMENTS TO
THE COMPLAINT
Date Action Filed:
Trial Date:
January 26, 2012
April 29, 2013
Defendants.
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Pursuant to Local Rule 6-1(a), and with the agreement of the Court's ADR Unit, Plaintiff
Jameson Ashley and Defendant City and County of San Francisco, by and through their attorneys of
record, hereby stipulate and agree that (1) the time to complete court mediation in this matter shall be
extended until and through October 30, 2012; and (2) the time for plaintiff to file an amended
complaint shall be extended until and through October 30, 2012.
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Joint Stipulation and Order re Deadlines
Ashley v. CCSF, et al.; Case No. CV-12-0045
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IT IS SO STIPULATED.
Dated: August 29, 2012
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DENNIS J. HERRERA
City Attorney
JOANNE HOEPER
Chief Trial Deputy
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Deputy City Attorney
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By: /s/
LEILA K. MONGAN
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Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
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Dated: August 29, 2012
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SIMS, CURRAN & OCKEN
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By: /s/
STUART R. CURRAN
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Attorneys for Plaintiff
JAMESON ASHLEY
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DECLARATION OF LEILA K. MONGAN
I, Leila K. Mongan, declare as follows:
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I am a deputy city attorney in the San Francisco City Attorney's Office. I am the
deputy primarily assigned to handle this case on behalf of the City and County of San Francisco. By
virtue of my direct involvement in the matter, I have personal knowledge of the contents of this
declaration, and I could and would competently testify to the truth of the matters stated.
2.
The parties have stipulated to extend the time in which to complete court mediation so
that they may take additional discovery prior to mediation. Due to scheduling difficulties and
discovery disputes, the parties have not been able to complete all depositions prior to the August 31,
2012 deadline for court mediation.
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Joint Stipulation and Order re Deadlines
Ashley v. CCSF, et al.; Case No. CV-12-0045
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Case3:12-cv-00045-JSW Document43 Filed08/31/12 Page3 of 3
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3.
The parties have stipulated to extend the time in which plaintiff may amend his
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complaint so that plaintiff may take additional discovery. Due to scheduling difficulties and discovery
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disputes, the parties have not been able to complete all depositions prior to the August 31, 2012
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deadline for plaintiff to amend his complaint.
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4.
There have been three previous stipulated time modifications in this case. The parties
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stipulated to extend the deadline for defendants to respond to plaintiff's complaint; the parties
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stipulated to extend the deadline in which to complete mediation; and the parties stipulated to extend
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the time for plaintiff to amend his complaint.
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5.
This requested time modification may affect the deadlines for fact and expert discovery,
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which are presently set for September 28, 2012 and November 23, 2012, respectively. The parties will
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confer and file a motion to modify the Court's Order Scheduling Trial and Pretrial Matters to amend
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those dates as necessary.
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I declare under penalty of perjury under the laws of the United States that the foregoing is true
and correct, and that I signed this declaration on August 29, 2012, at San Francisco, California.
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Leila K. Mongan
LEILA K. MONGAN
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ORDER
Based on the above stipulation, and for good cause appearing, IT IS ORDERED as follows:
The deadline for the parties to complete court mediation in this case is hereby extended until
and including October 30, 2012.
The deadline for plaintiff to file an amended complaint is hereby extended until and including
October 30, 2012.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Dated: August 31, 2012
THE HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT JUDGE
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Joint Stipulation and Order re Deadlines
Ashley v. CCSF, et al.; Case No. CV-12-0045
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