Nava, et al v. City of Shafter

Filing 45

STIPULATION and ORDER 44 Amending the Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 10/24/2013. (Hall, S)

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARK A. NAVA, GLORIA D. NAVA, and
MONIQUE A. NAVA
Plaintiffs,

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vs.
CITY OF SHAFTER, and DOES 1 to 100,
Inclusive,
Defendants.

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) CASE NO.: 1:12-CV-00010-AWI-JLT
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) STIPULATION AND ORDER AMENDING THE
) SCHEDULING ORDER
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STIPULATION

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Undersigned counsel for Plaintiffs, MARK A. NAVA, GLORIA D. NAVA, AND MONIQUE

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A. NAVA, and undersigned counsel for Defendants, CITY OF SHAFTER and DOES 1 to 100, all of the

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parties who have appeared and remain in this action, hereby stipulate and agree as follows:
RECITALS

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Whereas:

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1. The currently scheduled deadline to end Non-Expert disclosure is November 1, 2013, the Parties

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hereby stipulate to extend that cut off to November 7, 2013.

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2. Undersigned counsel stipulate and agree that the Court should enter an Order amending the

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scheduling order in this case for the only purpose of extending the non-expert discovery cut off

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to November 7, 2013. No other changes are requested or stipulated to.
3. The parties so stipulate because:
(a) The final deposition of a Person Most Qualified with a production of documents was
scheduled on today’s date, October 22, 2013;
(b) Documents, including the learning domains, were provided were provided on a CD, and
were not reviewable by counsel at the time of the deposition;
(c) The deponent also had an outstanding question pending to POST regarding the timeliness
of the documents provided;
(d) To have the opportunity to review the documents and have the outstanding question
answered, the parties agreed to adjourn the deposition to another date;

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(e) Due to Counsel and deponent’s schedules, the first day available is November 6, 2013;

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(f) Therefore, the parties would request that the Court extend the Non-expert discovery

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deadline to November 7, 2013 for the sole purpose of finishing the deposition of the

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Person Most Qualified.

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Dated: October 23, 2013

RODRIGUEZ & ASSOCIATES
/s/ Martha Rossiter
By: ?
DANIEL RODRIGUEZ, ESQ.
JOEL T. ANDREESON, ESQ.
MARTHA ROSSITER, ESQ.
Attorneys for Plaintiffs
MARK A. NAVA, GLORIA D. NAVA, AND
MONIQUE A. NAVA

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Dated: October 23, 2013

WALL, WALL & PEAKE

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/s/ Michael Allford

By:

MICHAEL ALLFORD, ESQ.
Attorney for Defendant
CITY OF SHAFTER

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ORDER
Based upon the stipulation of the parties, IT IS HEREBY ORDERED: The parties SHALL

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complete all discovery pertaining to non-experts on or before November 7, 2013. All other deadlines

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in the Court’s scheduling order shall remain the same.

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IT IS SO ORDERED.
Dated:

October 24, 2013

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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