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- 1 - 

 STIPULATION AND PROPOSED ORDER AMENDING MODIFIED 

PRETRIAL DEADLINES; CASE NO. CV 08 4022 SI 2360698.2

ROBERT R. MOORE (BAR NO. 113818) 

MICHAEL J. BETZ (BAR NO. 196228) 

ALLEN MATKINS LECK GAMBLE 

 MALLORY & NATSIS LLP 

Three Embarcadero Center, 12th Floor 

San Francisco, CA 94111-4074 

Phone: (415) 837-1515 

Fax: (415) 837-1516 

E-Mail: mbetz@allenmatkins.com 

GONZALEZ & LEIGH LLP 

MATT GONZALEZ (SBN 153486) 

G. WHITNEY LEIGH (SBN 153457) 

MATT SCHULTZ (SBN 220641) 

744 Montgomery Street, Fifth Floor 

San Francisco, CA 94111 

Telephone: (415) 512-2000 

Facsimile: (415) 512-2001 

Attorneys for Plaintiff 

Mitchell Engineering, a California corporation 

DENNIS J. HERRERA - State Bar #139669 

City Attorney 

GEORGE K. WONG - State Bar #75228 

RONALD P. FLYNN - State Bar #184186 

LOUISE S. SIMPSON - State Bar #115253 

DAVID L. NORMAN - State Bar #148556 

Deputy City Attorneys 

Fox Plaza 

1390 Market Street, 4th Floor 

San Francisco, CA 94102-5408 

Telephone: (415) 554-3901 

Facsimile: (415) 255-0733 

ronald.flynn@sfgov.org 

HANSON BRIDGETT LLP 

ANDREW G. GIACOMINI, State Bar # 154377 

agiacomini@hansonbridgett.com 

JEFFREY M. CHU - 121381 

jchu@hansonbridgett.com 

S. ANNE JOHNSON - 197415 

ajohnson@hansonbridgett.com 

425 Market Street, 26th Floor 

San Francisco, CA 94105 

Telephone: (415) 777-3200 

Facsimile: (415) 541-9366 

Attorneys for Defendants 

CITY AND COUNTY OF SAN FRANCISCO, ANTHONY 

IRONS, MICHAEL QUAN, AND ALAN WONG 

Case 3:08-cv-04022-SI Document 143 Filed 05/25/10 Page 1 of 4 Case3:08-cv-04022-SI Document142 Filed05/21/10 Page1 of 4
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- 2 - 

 STIPULATION AND PROPOSED ORDER AMENDING MODIFIED 

PRETRIAL DEADLINES; CASE NO. CV 08 4022 SI 2360698.2

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

MITCHELL ENGINEERING, a California 

corporation, 

Plaintiff, 

vs.

CITY AND COUNTY OF SAN FRANCISCO, 

a political subdivision of the State of California; 

ANTHONY IRONS, in his individual capacity 

and, alternatively, in his official capacity as 

Assistant General Manager of the San Francisco 

Public Utilities Commission; 

MICHAEL QUAN, in his individual capacity 

and, alternatively, in his official capacity as 

Director of Construction Management Bureau 

of the San Francisco Public Utilities 

Commission; ALAN WONG, in his individual 

capacity and, alternatively, in his official 

capacity as Safety Manager of the San 

Francisco Public Utilities Commission; and 

DOES 1 through 10, inclusive, 

Defendants. 

Case No. CV 08 4022 SI 

STIPULATION AND [PROPOSED] ORDER 

AMENDING MODIFIED PRE-TRIAL DEADLINES 

AND TRIAL DATE

It is stipulated by and between counsel for Plaintiff MITCHELL ENGINEERING and 

counsel for Defendants CITY AND COUNTY OF SAN FRANCISCO, ANTHONY IRONS, 

MICHAEL QUAN, and ALAN WONG that the Order Modifying Pretrial Deadlines filed by the 

Court on March 10, 2010, be amended as follows, to permit the parties the opportunity to 

mediate on May 27 and 28, 2010 this case as well as the 5 State cases regarding the 5 Public 

Utilities Commission projects: 

1. Mitchell Engineering to provide supplemental discovery responses per May 17, 

2010 Order: move from June 2, 2010 to June 16, 2010;

2. Expert rebuttal: move from June 2, 2010 to June 16, 2010;

3. Expert Discovery Cut-off: move from July 2, 2010 to July 16, 2010;

4. Motion for Summary Judgment Oppositions: move from May 28, 2010 to June 11, 

2010;

Case 3:08-cv-04022-SI Document 143 Filed 05/25/10 Page 2 of 4 Case3:08-cv-04022-SI Document142 Filed05/21/10 Page2 of 4
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- 3 - 

 STIPULATION AND PROPOSED ORDER AMENDING MODIFIED 

PRETRIAL DEADLINES; CASE NO. CV 08 4022 SI 2360698.2

5. Mitchell Summary Judgment Reply: move from June 4, 2010 to June 18, 2010;

6. 'HIHQGDQWV¶ Summary Judgment Replies move from June 11, 2010 to June 25, 

2010;

7. Hearing on Dispositive Motions move from June 18, 2010 to on or after July 2, 

2010;

8. Pretrial conference date: move from July 20, 2010 to August 17, 2010; and 

9. Jury trial date: move from August 2, 2010 to August 30, 2010 at 8:30 a.m. in 

Courtroom 10, 19th Floor. 

IT IS SO STIPULATED. 

Dated: May 21, 2010 ALLEN MATKINS LECK GAMBLE & 

MALLORY & NATSIS LLP 

ROBERT R. MOORE, ESQ, (SBN 113818) 

MICHAEL J. BETZ, ESQ. (SBN 196228) 

By: /s/ Robert R. Moore

ROBERT R. MOORE 

Attorneys for Plaintiffs 

MITCHELL ENGINEERING 

Dated: May 21, 2010 HANSON BRIDGETT LLP 

By: /s/ S. Anne Johnson 

S. ANNE JOHNSON 

Attorneys for Defendants 

CITY AND COUNTY OF SAN 

FRANCISCO, a political subdivision of the 

State of California; ANTHONY IRONS, in 

his individual capacity and, alternatively, in 

his official capacity as Assistant General 

Manager of the San Francisco Public 

Utilities Commission; MICHAEL QUAN, 

in his individual capacity and, alternatively, 

in his official capacity as Director of 

Construction Management Bureau of the 

San Francisco Public Utilities Commission; 

ALAN WONG, in his individual capacity 

and, alternatively, in his official capacity as 

Safety Manager of the San Francisco Public 

Utilities Commission 

Case 3:08-cv-04022-SI Document 143 Filed 05/25/10 Page 3 of 4 Case3:08-cv-04022-SI Document142 Filed05/21/10 Page3 of 4
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- 4 - 

 STIPULATION AND PROPOSED ORDER AMENDING MODIFIED 

PRETRIAL DEADLINES; CASE NO. CV 08 4022 SI 2360698.2

IT IS HEREBY ORDERED THAT

1. Mitchell Engineering shall provide the supplemental discovery responses required 

E\WKLV&RXUW¶V May 17, 2010 Order on or before June 16, 2010; 

2. The expert rebuttal deadline shall be June 16, 2010;

3. Expert Discovery Cut-off shall be July 16, 2010;

4. Motion for Summary Judgment Oppositions shall be due June 11, 2010;

5. Mitchell¶V Summary Judgment Reply shall be due June 18, 2010;

6. 'HIHQGDQWV¶ Summary Judgment Replies shall be due June 25, 2010;

7. Hearing on Dispositive Motions will occur on July 2, 2010 [or ] at ;

8. The Pretrial Conference is set for August 17, 2010 [or ] at ;

and

9. Jury trial date: August 30, 2010 [or ] at 8:30 a.m. in Courtroom 

10, 19th Floor. 

Dated: 

HON. SUSAN ILLSTON 

UNITED STATES DISTRICT COURT 

JUDGE 

Case3:08-cv-04022-SI Document142 Filed05/21/10 Page4 of 4

The further case management conference has been continued to

Friday, July 2, 2010, at 3:00 p.m.

Case 3:08-cv-04022-SI Document 143 Filed 05/25/10 Page 4 of 4