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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES 

Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG 

Gregory M. Fox, State Bar No. 070876 

Joanne Tran, State Bar No. 294402 

Heidi G. Kim, State Bar No. 306641 

BERTRAND, FOX, ELLIOT, OSMAN & WENZEL 

The Waterfront Building 

2749 Hyde Street 

San Francisco, California 94109 

Telephone: (415) 353-0999 

Facsimile: (415) 353-0990 

Email: gfox@bfesf.com

jtran@bfesf.com

hkim@bfesf.com

Attorneys for Defendant 

OFFICER DENNIS MALLY 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA 

RON FRANKLIN, an individual 

 Plaintiff, 

v. 

CITY OF SAN LEANDRO, a municipal 

corporation; DENNIS MALLY, individually 

and in his capacity as an officer for the San 

Leandro Police Department; and DOES 1-25, 

inclusive, individually, jointly and severally, 

 Defendants. 

Case No. 4:17-cv-00789-HSG 

STIPULATION AND ORDER TO EXTEND 

EXPERT DISCOVERY DEADLINES 

Hon. Haywood S. Gilliam, Jr. 

Pursuant to Federal Rules of Civil Procedure Rule 16(b)(4), and the Scheduling Order issued by 

United States District Judge Haywood S, Gilliam Jr. on September 27, 2018 (the “Scheduling Order”), 

(Dkt. No. 37.) Plaintiff RON FFRANKLIN and Defendant DENNIS MALLY by and through 

undersigned counsel, hereby jointly stipulate and move to extend expert discovery deadlines for good 

cause as follows: 
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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES 

Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG 

1. Pursuant to the Scheduling Order, the cut-off for: 

 Exchange of opening expert reports is March 12, 2019. 

 Exchange of rebuttal expert reports is March 27, 2019. 

 Close of expert discovery is April 11, 2019. 

2. The parties have met and conferred and agree that an additional 30 days extension is 

necessary to permit the parties to sufficiently complete expert discovery. 

3. This is the first request to continue expert discovery deadlines. This extension will not 

affect the trial date or any other dates previously set by the Court. 

4. For the reasons set forth above, the parties respectfully request that this Court continue the 

previously set expert discovery deadlines as follows: 

 Exchange of opening expert reports to April 11, 2019. 

 Exchange of rebuttal expert reports to April 26, 2019. 

 Close of expert discovery to May 10, 2019. 

IT IS SO STIPULATED AND REQUESTED THROUGH THE PARTIES’ COUNSELS OF 

RECORD. 

Dated: March 8, 2019 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL 

 By: /s/ Joanne Tran 

 Gregory M. Fox 

 Joanne Tran 

 Heidi Kim 

 Attorneys for Defendant 

 OFFICER DENNIS MALLY 

Dated: March 8, 2019 LAW OFFICES OF JOHN L. BURRIS 

 By: /s/ K. Chike Odiwe 

 John L. Burris 

 DeWitt Lacy 

 K. Chike Odiwe 

 Attorneys for Plaintiff 

 RON FRANKLIN 
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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES 

Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG 

ATTORNEY ATTESTATION 

 I hereby attest that I have on file all holograph signatures for any signatures indicated by a 

conformed signature (“/s/”) within this E-filed document or have been authorized by Plaintiff’s counsel 

to show their signature on this document as /s/. 

Dated: March 8, 2019 By: /s/ Joanne Tran 

 Joanne Tran 
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STIPULATION AND ORDER TO EXTEND EXPERT DISCOVERY DEADLINES 

Franklin v. City of San Leandro, et al. U.S.D.C. Northern District Case No.: 4:17-cv-00789-HSG 

ORDER 

GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the 

following deadlines have been extended to 30 days: 

 Exchange of opening expert reports is April 11, 2019 

 Exchange of rebuttal expert reports is April 26, 2019. 

 Close of expert discovery is May 10, 2019. 

IT IS SO ORDERED. 

Dated: March 11, 2019 

Hon. Haywood S. Gilliam, Jr. 

UNITED STATES DISTRICT JUDGE