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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PLAINTIFF TO SERVE REBUTTAL 

EXPORT REPORT 

CASE NO. C-05-1858-MHP (PR) 

433410.01 

KEKER & VAN NEST, LLP 

ASHOK RAMANI - #200020 

BROOK DOOLEY - #230423 

JENNIFER A. HUBER - #250143 

710 Sansome Street 

San Francisco, CA 94111-1704 

Telephone: (415) 391-5400 

Facsimile: (415) 397-7188 

Attorneys for Plaintiff 

ZAMEER RIAZ AZAM 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

ZAMEER RIAZ AZAM, 

Plaintiff, 

v. 

OFFICER M. JOHNSON, 

Defendant. 

 

Case No. C-05-1858-MHP (PR) 

STIPULATION AND [PROPOSED] 

ORDER EXTENDING TIME FOR 

PLAINTIFF TO SERVE REBUTTAL 

EXPORT REPORT 

Dept: Courtroom 15, 18th Floor 

Judge: Hon. Marilyn Hall Patel 

Trial Date: February 17, 2009 

Case 3:05-cv-01858-MHP Document 53 Filed 01/06/09 Page 1 of 3
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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PLAINTIFF TO SERVE REBUTTAL 

EXPORT REPORT 

CASE NO. C-05-1858-MHP (PR) 

433410.01 

Pursuant to Local Rules 6-2 and 7-12 of the Northern District of California, it is hereby 

stipulated and agreed by Plaintiff Zameer Riaz Azam and Defendant Mark Johnson, by and 

through their attorneys, as follows: 

WHEREAS, by Order dated September 22, 2008, the Court set the date for expert 

disclosure on December 12, 2008, and the date for rebuttal expert disclosure on January 5, 2009; 

WHEREAS, Defendant Mark Johnson’s expert witness disclosure listed Captain David 

Pascoe as a non-retained expert; 

WHEREAS, Defendant Mark Johnson did not serve a Rule 26(a)(2)(B) expert report for 

Captain Pascoe; 

WHEREAS, Captain Pascoe had a pre-planned vacation set for the two weeks prior to 

January 5, 2009, and was thus not available for deposition during that time; and 

WHEREAS, Captain Pascoe is available for deposition on January 8, 2009, and will be 

deposed by Plaintiff’s counsel on that date; 

IT IS HEREBY STIPULATED that Plaintiff shall have until January 16, 2009, to serve a 

rebuttal expert report with respect to Captain Pascoe’s expert opinions. Plaintiff’s counsel will 

serve its rebuttal expert report with respect to Captain Pascoe’s expert opinions on Defendant’s 

counsel by electronic mail on January 16, 2009. Plaintiff will produce his expert for deposition 

regarding rebuttal reports on January 21, 2009. 

Dated: December 31, 2008 KEKER & VAN NEST, LLP 

By: /s/ Brook Dooley 

BROOK DOOLEY 

Attorneys for Plaintiff 

ZAMEER RIAZ AZAM 

Dated: December 31, 2008 COUNTY OF CONTRA COSTA 

By: /s/ Monika L. Cooper 

MONIKA L. COOPER 

Attorneys for Defendant 

MARK JOHNSON 

Case 3:05-cv-01858-MHP Document 53 Filed 01/06/09 Page 2 of 3
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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR PLAINTIFF TO SERVE REBUTTAL 

EXPORT REPORT 

CASE NO. C-05-1858-MHP (PR) 

433410.01 

I, Brook Dooley, am the ECF user whose ID and password are being used to file this 

STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT. In compliance with 

General Order 45, X.B., I hereby attest that Monica L. Cooper has concurred in this filing. 

[PROPOSED] ORDER 

Pursuant to stipulation, IT IS SO ORDERED. 

Dated: January ___, 2009. ____________________________________ 

 The Honorable Marilyn Hall Patel 

 United States District Court Judge 

5

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:05-cv-01858-MHP Document 53 Filed 01/06/09 Page 3 of 3