City and County of San Francisco v. City of Oakland

STIPULATION REGARDING AMENDMENT OF
CASE MANAGEMENT DEADLINES AND
[PROPOSED] ORDER
CASE NO. 3:24-CV-02311-TSH
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FENNEMORE LLP
FENNEMORE CRAIG, P.C.
OAKLAND/SEATTLE
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO,
Plaintiff,
v.
CITY OF OAKLAND AND PORT OF
OAKLAND,
Defendants.
Case No. 3:24-cv-02311-TSH
STIPULATION REGARDING
AMENDMENT OF CASE
MANAGEMENT DEADLINES;
[PROPOSED] ORDER AS
MODIFIED BY THE COURT
CITY OF OAKLAND, A MUNICIPAL
CORPORATION, ACTING BY AND
THROUGH ITS BOARD OF PORT
COMMISSIONERS (PORT OF OAKLAND),
Counterclaimant,
v.
CITY AND COUNTY OF SAN FRANCISCO,
Counterclaim Defendant.
Case 3:24-cv-02311-TSH Document 128 Filed 12/04/25 Page 1 of 5

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STIPULATION REGARDING AMENDMENT OF
CASE MANAGEMENT DEADLINES AND
[PROPOSED] ORDER
CASE NO. 3:24-CV-02311-TSH
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FENNEMORE LLP
FENNEMORE CRAIG, P.C.
OAKLAND/SEATTLE
STIPULATION
Plaintiff City and County of San Francisco (the “City”), and Defendant and
Counterclaimant the City of Oakland, a municipal corporation, acting by and through its Board of
Port Commissioners (the “Port”), (together, the “Parties” and, each, a “Party”), by and through
their undersigned attorneys, hereby stipulate and agree pursuant to Federal Rule of Civil
Procedure 16(b)(4), and Civil Local Rules 7-12 and 16-2 as follows:
 WHEREAS, this Court entered the Case Management Order on December 12, 2024 (Dkt.
86);
 WHEREAS, on April 11, 2025, the Parties stipulated to modifying the case schedule
while the Parties attempted a second mediation (Dkt. 95);
 WHEREAS, the Parties were unable to resolve this litigation in that mediation, and have
since been diligently engaged in discovery;
 WHEREAS, on September 3, 2025, the Parties stipulated to modifying the case schedule
and the Court entered a new Case Management Order based upon that stipulation and
finding of good cause (Dkt. 111);
 WHEREAS, the Parties have been actively engaged in discovery and the Parties have
been diligent in pursuing discovery and observing the Case Management Deadlines;
 WHEREAS, the Parties are in the process of scheduling a mediation session with the
Mediator at JAMS with whom the Parties mediated in April 2025, and the Parties are
seeking to schedule that mediation to occur this month;
 WHEREAS, the parties continue to collect, review, and produce electronically stored
information and are pursuing multiple third-party document and deposition subpoenas
such that, in light of settlement discussions and despite the Parties’ diligence, more time
will be needed to complete fact discovery; and
 WHEREAS, the Parties believe that good cause exists and it is in the interests of judicial
economy to continue the Case Management Deadlines to allow the Parties to focus on
Case 3:24-cv-02311-TSH Document 128 Filed 12/04/25 Page 2 of 5

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STIPULATION REGARDING AMENDMENT OF
CASE MANAGEMENT DEADLINES AND
[PROPOSED] ORDER
CASE NO. 3:24-CV-02311-TSH
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FENNEMORE LLP
FENNEMORE CRAIG, P.C.
OAKLAND/SEATTLE
settlement efforts, while providing sufficient time for the parties to prepare their
respective cases should the forthcoming mediation not result in a settlement.
Therefore, the Parties respectfully request that this Court enter the attached proposed
order amending the Case Management Deadlines as follows:
CASE MANAGEMENT EVENT 	DEADLINE
(Dkt. 111)
PROPOSED
AMENDED
DEADLINE
Close of Fact Discovery 	2/27/2026 	5/27/2026
Disclosure of Expert Witnesses 	3/31/2026 	6/1/2026
Disclosure of Rebuttal Expert Witnesses 	5/8/2026 	8/10/2026
Close of Expert Discovery 	6/5/2026 	9/8/2026
Deadline to File Dispositive Motions 	8/6/2026 	11/6/2026
Hearing on Dispositive Motions 	9/10/2026 	12/10/2026
Exchange of Pretrial Disclosures 	11/13/2026 	1/13/2027
Deadline to File Pretrial Documents 	12/4/2026 	3/4/2027
Deadline to File Oppositions to Motions in Limine 	12/11/2026 	3/11/2027
Pretrial Conference 	1/14/2027 	4/14/2027
Final Pretrial Conference 	2/11/2027 	5/11/2027
Jury Trial (Duration to be determined) 	2/22/2027 	5/24/2027
IT IS SO STIPULATED.
Case 3:24-cv-02311-TSH Document 128 Filed 12/04/25 Page 3 of 5

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STIPULATION REGARDING AMENDMENT OF
CASE MANAGEMENT DEADLINES AND
[PROPOSED] ORDER
CASE NO. 3:24-CV-02311-TSH
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FENNEMORE LLP
FENNEMORE CRAIG, P.C.
OAKLAND/SEATTLE
Dated: December 4, 2025 	FENNEMORE LLP & FENNEMORE CRAIG,
P.C.
By: /s/ Brandi B. Balanda
Eugene M. Pak
Stephen C. Willey
Brandi B. Balanda
Sarah Gohmann Bigelow
Attorneys for Defendant and
Counterclaimant City of Oakland, a
municipal corporation, acting by and
through its Board of Port Commissioners
(Port of Oakland)
Dated: December 4, 2025 	COOLEY LLP
By: /s/ Judd Lauter
Bobby Ghajar
Judd Lauter
John Hemann
Ryan Stevens
Jessica Williams
Attorneys for Plaintiff and Counterclaim
Defendant City and County of San
Francisco
Case 3:24-cv-02311-TSH Document 128 Filed 12/04/25 Page 4 of 5

STIPULATION REGARDING AMENDMENT OF
CASE MANAGEMENT DEADLINES AND
[PROPOSED] ORDER
CASE NO. 3:24-CV-02311-TSH
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FENNEMORE LLP
FENNEMORE CRAIG, P.C.
OAKLAND/SEATTLE
ORDER AS MODIFIED BY THE COURT
PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED:
The deadlines set forth in the September 3, 2025 Case Management Order (Dkt. 111), are
amended as follows:
SUMMARY OF CASE MANAGEMENT DEADLINES
Close of Fact Discovery 	5/27/2026
Disclosure of Expert Witnesses 	6/1/2026
Disclosure of Rebuttal Expert Witnesses 	8/10/2026
Close of Expert Discovery 	9/8/2026
Deadline to File Dispositive Motions 	11/6/2026
Hearing on Dispositive Motions 	12/10/2026
Exchange of Pretrial Disclosures 	1/13/2027
Deadline to File Pretrial Documents 	3/4/2027
Deadline to File Oppositions to Motions in Limine 	3/11/2027
Pretrial Conference 	4/14/2027
Final Pretrial Conference 	5/11/2027
Jury Trial (Duration to be determined) 	5/24/2027
IT IS SO ORDERED.
Dated: December 4, 2025. By:______________________________
Magistrate Judge Thomas S. Hixson
11/5/2026
4/15/2027
5/13/2027
Case 3:24-cv-02311-TSH Document 128 Filed 12/04/25 Page 5 of 5