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STIPULATION EXTENDING CLOSE OF DISCOVERY AND CONTINUING SUMMARY JUDGMENT 

BRIEFING SCHEDULE PURSUANT TO CIV. L. R. 6-1 

CASE NO. 3:09-cv-00683-MHP 

496282.02 

KEKER & VAN NEST, LLP 

DANIEL PURCELL (SB # 191424) 

AJAY S. KRISHNAN (SB# 222476) 

DANIEL K. NAZER (SB# 257380) 

710 Sansome Street 

San Francisco, CA 94111-1704 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

Attorneys for Plaintiffs 

Derek E. Turner and Mari Toban Blome 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

DEREK E. TURNER and MARI TOBAN 

BLOME, 

Plaintiffs, 

v. 

KRIS LAFOND; MEG PLANKA; DANIEL 

SCHNEIDER; CALIFORNIA HIGHWAY 

PATROL COMMISSIONER J.A. FARROW; 

THE GOLDEN GATE BRIDGE, HIGHWAY 

AND TRANSPORTATION DISTRICT and 

Does 1 through 20, 

Defendants. 

 

Case No. 3:09-cv-00683-MHP 

STIPULATION EXTENDING CLOSE 

OF DISCOVERY AND CONTINUING 

SUMMARY JUDGMENT BRIEFING 

SCHEDULE PURSUANT TO CIV. L. R. 

6-1 

 

Case 3:09-cv-00683-EMC Document 51 Filed 05/28/10 Page 1 of 5
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STIPULATION EXTENDING CLOSE OF DISCOVERY AND CONTINUING SUMMARY JUDGMENT 

BRIEFING SCHEDULE PURSUANT TO CIV. L. R. 6-1 

CASE NO. 3:09-cv-00683-MHP 

496282.02 

Pursuant to Civil Local Rules 6-1(b) and 7-12, Plaintiffs Derek E. Turner and Mari Toban 

Blome (“Plaintiffs”) and Defendants Kris Lafond, Margaret Planka, Daniel Schneider, the 

California Highway Patrol Commissioner J.A. Farrow, and The Golden Gate Bridge Highway 

and Transportation District (collectively the “Parties”), hereby stipulate to the following: 

WHEREAS, Plaintiff Derek E. Turner filed his initial complaint in this proceeding on 

February 17, 2009; 

WHEREAS, Plaintiffs Derek E. Turner and Mari Toban Blome filed their First 

Amended Complaint on October 13, 2009; 

WHEREAS, there has been only one prior time modification in this case whereby, 

pursuant to a stipulation, the Court continued the hearing on Plaintiff Derek E. Turner’s Motion 

for Leave to File First Amended Complaint for one week from 2:00 p.m. on September 21, 2009 

to 3:00 p.m. on September 28, 2009 so that it could be heard concurrently with an already 

scheduled case management conference; 

WHEREAS, at a case management conference on January 11, 2010, the Court ordered 

that: 

1) CIC Witness list by May 17, 2010; 

2) Expert Designation/Final Reports by May 17, 2010; 

3) Completion of all discovery by June 14, 2010; 

4) Summary Judgment motions to be filed by July 26, 2010; 

5) Oppositions to be filed by August 16, 2010; 

6) Replies to be filed by August 23, 2010; 

7) Motions to be heard 2:00 p.m. on September 13, 2010; 

WHEREAS, the Parties have been diligently conducting discovery in this case pursuant 

to the Court’s schedule and the Defendants have designated four expert witness;

WHEREAS, the Parties agree that, in the interests of fairness and efficiency, and in light 

of the large volume of electronic discovery in this case and the need for multiple expert 

depositions, the deadline for the close of all discovery in this case should be extended until July 

Case 3:09-cv-00683-EMC Document 51 Filed 05/28/10 Page 2 of 5
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STIPULATION EXTENDING CLOSE OF DISCOVERY AND CONTINUING SUMMARY JUDGMENT 

BRIEFING SCHEDULE PURSUANT TO CIV. L. R. 6-1 

CASE NO. 3:09-cv-00683-MHP 

496282.02 

12, 2010. 

WHEREAS, the Parties also agree that, the purpose of the extended deadline for close of 

discovery is to permit the completion of existing discovery, and not for the purpose of 

propounding new discovery that could not have been propounded under the current discovery 

cut-off. As such, for purposes of determining whether discovery was timely propounded, absent 

mutual consent, the original deadline of June 14, 2010 will apply. 

WHEREAS, the Parties agree that, to accommodate the extension in the discovery 

schedule, the deadlines for summary judgment motions should be extended by four weeks.

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and 

between the Parties, through their respective attorneys, that pursuant to Northern District Civil 

Local Rule 6-1(a) that: 

1) The deadline for completion of all discovery be extended to July 12, 2010; 

2) For purposes of determining whether discovery was timely propounded, absent 

mutual consent, the original discovery deadline of June 14, 2010 shall apply; 

2) Summary Judgment motions to be filed by August 23, 2010; 

3) Oppositions to be filed by September 13, 2010; 

4) Replies to be filed by September 20, 2010; 

5) Motions to be heard 2:00 p.m. on October 18, 2010. 

DATED: May 26, 2010 KEKER AND VAN NEST LLP 

By _/s/ Daniel Nazer _______________ 

 DANIEL PURCELL 

 AJAY S. KRISHAN 

DANIEL K. NAZER 

Attorneys For Plaintiffs 

DEREK E. TURNER and 

MARI TOBAN BLOME 

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STIPULATION EXTENDING CLOSE OF DISCOVERY AND CONTINUING SUMMARY JUDGMENT 

BRIEFING SCHEDULE PURSUANT TO CIV. L. R. 6-1 

CASE NO. 3:09-cv-00683-MHP 

496282.02 

DATED: May 26, 2010 OFFICE OF THE ATTORNEY 

GENERAL OF CALIFORNIA 

 By _/s/ John Devine___________________ 

 EDMUND G. BROWN 

 PAUL T. HAMMERNESS 

 JOHN P. DEVINE 

 Attorneys For Defendants 

 CHP OFFICERS KRIS LAFOND, 

 MARGARET PLANKA, and DANIEL 

 SCHNEIDER 

Filer’s Attestation: Pursuant to General 

Order No. 45, Section X.B. regarding 

nonfiling signatories, Daniel K. Nazer 

hereby attests that concurrence in the filing 

of this stipulation has been obtained by 

John P. Devine 

DATED: May 26, 2010 HANSON BRIDGETT LLP 

By: /s/ Julie Veit 

KIMON MANOLIUS 

JULIA H. VEIT 

SOPHIA B. BELLOI 

MARGARET E. COHEN 

Attorneys for Defendant 

GOLDEN GATE BRIDGE, HIGHWAY 

AND TRANSPORTATION DISTRICT 

Filer’s Attestation: Pursuant to General 

Order No. 45, Section X.B. regarding 

nonfiling signatories, Daniel K. Nazer 

hereby attests that concurrence in the filing 

of this stipulation has been obtained by 

Julia H. Veit 

5/27/2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

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STIPULATION EXTENDING CLOSE OF DISCOVERY AND CONTINUING SUMMARY JUDGMENT 

BRIEFING SCHEDULE PURSUANT TO CIV. L. R. 6-1 

CASE NO. 3:09-cv-00683-MHP 

496282.02 

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

Dated: May ___, 2010 

 

MARILYN HALL PATEL 

United States District Court Judge 

Case 3:09-cv-00683-EMC Document 51 Filed 05/28/10 Page 5 of 5