Corona v. Knowles et al

Filing 154

STIPULATION Regarding Expert Disclosures; ORDER, signed by District Judge Lawrence J. O'Neill on 7/13/2012. (IT IS SO ORDERED that the parties stipulation regarding expert disclosures is approved. The disclosures for Plaintiffs correctional expert shall occur on or before 8/8/2012. All other disclosures shall occur on or before 7/17/2012, consistent with this Courts prior order 129 .) (Gaumnitz, R)

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BINGHAM MCCUTCHEN LLP
WARREN E. GEORGE (SBN 53588)
MANU PRADHAN (SBN 253026)
Three Embarcadero Center
San Francisco, CA 94111-4067
Telephone:
415.393.2000
Facsimile:
415.393.2286
Email:
[e-mail]
[e-mail]
EDWARD A. ANDREWS (SBN 268479)
The Water Garden
Fourth Floor, North Tower
1620 26th Street
Santa Monica, CA 90404-4060
Telephone:
310.907.1000
Facsimile:
310.907.2000
Email:
[e-mail]

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COURTNEY E. SMITH (SBN 273598)
1117 S. California Avenue
Palo Alto, CA 94304
Telephone: [phone]
Facsimile: 650.849.4800
Email:
[e-mail]
Attorneys for Plaintiffs Maria del Rosario
Corona and Andres Santana

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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MARIA DEL ROSARIO CORONA, AS HEIR
OF THE ESTATE OF OSCAR CRUZ, et. al.,
Plaintiffs,

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Case No. 1:08-CV-00237-LJO-DLB
STIPULATION REGARDING
EXPERT DISCLOSURES; ORDER

v.
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MARTIN BITER, et al.,
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Defendants.
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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING EXPERT DISCLOSURES
A/75025831.1

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STIPULATION

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Pursuant to Fed. R. Civ. Proc. 26(a)(2), the parties stipulate to an extension of the

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deadline regarding expert disclosures. Disclosures are due on July 17, 2012. (Dkt. No. 129.)

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This deadline was previously extended because of the need to extend fact discovery. (Id.)

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A short extension of time is necessary for the disclosures for a correctional expert

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Plaintiffs intend to call at trial. The correctional expert has recently experienced a death in the

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family. Since then, Plaintiffs’ contact with the expert has been extremely limited, and Plaintiffs

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do not currently know the expert’s availability, or whether he is able to devote sufficient time to

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the disclosures before they are due on the 17th. At the same time, Plaintiffs’ opposition to

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Defendants’ summary judgment motion is due August 3, 2012. (Dkt. No. 151.) So as not to

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interfere with that calendar item, and to minimize prejudice to Defendants, Plaintiffs request that

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the disclosure deadline for their correctional expert be extended until August 3. Plaintiffs

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believe their expert should be able to complete disclosures by August 3.

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Therefore, the parties stipulate that the disclosures for Plaintiffs’ correctional expert will

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be due on August 3. This stipulation does not affect the disclosure date for any other experts

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subject to a disclosure obligation.

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Date: July 13, 2012

BINGHAM MCCUTCHEN LLP

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By:

/s/
Manu Pradhan
Attorneys for Plaintiffs

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Date: July 13, 2012

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ATTORNEY GENERAL OF THE STATE OF
CALIFORNIA

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By:

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/s/
Kelli M. Hammond
Attorney for Defendants

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING EXPERT DISCLOSURES
A/75025831.1

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ORDER

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GOOD CAUSE showing, IT IS SO ORDERED that the parties’ stipulation regarding
expert disclosures is approved. The disclosures for Plaintiffs’ correctional expert shall occur on
or before August 3, 2012. All other disclosures shall occur on or before July 17, 2012, consistent
with this Court’s prior order (Dkt. No. 129).

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DATE: _______________, 2012

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By:

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Judge, United States District Court for the
Eastern District of California

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING EXPERT DISCLOSURES
A/75025831.1

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ATTESTATION OF FILER

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The signatories to this document are myself and Kelli Hammond, and I have
obtained Ms. Hammond’s concurrence to sign this document on her behalf.

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DATED: July 13, 2012

BINGHAM McCUTCHEN LLP

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By:

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/s/
Manu Pradhan
Attorneys for Plaintiffs

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IT IS SO ORDERED.

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Dated:

/s/ Lawrence J. O’Neill

July 13, 2012

UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:

66h44d

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Case No. 1:08-CV-00237-LJO-DLB

STIPULATION REGARDING EXPERT DISCLOSURES
A/75025831.1