Edison v. United States of America et al

Filing 121

STIPULATION and ORDER 120 to Set Settlement Conference and Modifying the Scheduling Order to Extend Time for Expert Discovery, signed by Magistrate Judge Jennifer L. Thurston on 2/15/2018. Expert discovery deadline 4/27/2018. Settlement Conference set for 3/5/2018 at 01:30 PM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. (Hall, S)

1 McGREGOR W. SCOTT
United States Attorney
2 ALYSON A. BERG
3 Assistant United States Attorney
2500 Tulare Street, Suite 4401
4 Fresno, California 93721
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Defendant
United States of America
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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11 GREGORY EDISON,
Plaintiff,

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v.

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14 UNITED STATES OF AMERICA; THE GEO
GROUP, INC.; MANAGEMENT AND
15 TRAINING CORPORATION,
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Case No. 1:12-cv-02026-AWI-JLT
STIPULATION AND [PROPOSED]
ORDER TO SET SETTLEMENT
CONFERENCE AND MODIFYING
SCHEDULING ORDER TO EXTEND
TIME FOR EXPERT DISCOVERY
(Doc. 120)

Defendants.

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Plaintiff Gregory Edison, and the Defendants United States of America (“United States”), and

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Management & Training Corporation (“MTC”) (collectively “the parties”), by and through their
respective counsel, respectfully submit this stipulation and proposed order setting a settlement
conference for March 5, 2018, and modifying the scheduling order to allow expert discovery to extend
beyond the dates currently set in the scheduling order. All parties have been engaging in settlement
discussions, and are interested in resolving the case without incurring further attorneys fees or costs.
Therefore, the parties request the assistance of the Honorable Jennifer L. Thurston to resolve this case
with a settlement conference at 10:00 a.m. on March 5, 2018, which date has been cleared with the
Court.
///

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STIPULATION AND [PROPOSED] ORDER TO SET SETTLEMENT CONFERENCE AND
MODIFYING SCHEDULING ORDER TO EXTEND TIME FOR EXPERT DISCOVERY

Edison v. United States of America, et al., Case No. 1:12-cv-02026-AWI-JLT

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Additionally, in an effort to focus on settlement negotiations, the parties, by and through their

2 respective counsel, stipulate and respectfully request the brief continuation of the expert dates outlined
3 below. The proposed date changes will not affect the November 6, 2018 trial date. The current and
4 proposed schedules are provided below for the Court’s reference.
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Current

Proposed

6 Plaintiff’s Expert Disclosures

2/23/2018

3/09/18

7 Defendants’ Expert Disclosures

3/09/2018

3/23/18

8 Rebuttal Expert Disclosures

3/23/2018
4/02/18
Respectfully submitted,

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DATED: February 13, 2018

McGREGOR W. SCOTT
United States Attorney

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By:

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BOUCHER, LLP

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16 DATED: February 13, 2018

(As authorized 02/13/18)

By:

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/s/Brian M. Bush/
HERMEZ MORENO
RAYMOND PAUL BOUCHER
MILIN CHUN
BRIAN M. BUSH
Attorneys for Plaintiff
BURKE, WILLIAMS & SORENSEN LLP

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21 DATED: February 13, 2018
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/s/Alyson A. Berg
ALYSON A. BERG
Assistant United States Attorney
Attorneys for Defendant,
United States of America

(As authorized 02/13/18)

By:

/s/Kristina D. Gruenberg
KRISTINA D. GRUENBERG
Attorneys for Defendant MTC

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STIPULATION AND [PROPOSED] ORDER TO SET SETTLEMENT CONFERENCE AND
MODIFYING SCHEDULING ORDER TO EXTEND TIME FOR EXPERT DISCOVERY

Edison v. United States of America, et al., Case No. 1:12-cv-02026-AWI-JLT

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ORDER

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Based upon the stipulation counsel, the Court ORDERS:

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1.

The Court sets a settlement conference on March 5, 2018 at 1:30 p.m.;

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2.

The case schedule is modified as follows:

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a.
b.

Defendants’ expert disclosure: March 23, 2018;

c.

Plaintiff’s rebuttal expert disclosure: April 2, 2018;

d.

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Plaintiff’s expert disclosure: March 9, 2018;

Expert discovery deadline: April 27, 2018

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11 IT IS SO ORDERED.
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Dated:

February 15, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER TO SET SETTLEMENT CONFERENCE AND
MODIFYING SCHEDULING ORDER TO EXTEND TIME FOR EXPERT DISCOVERY

Edison v. United States of America, et al., Case No. 1:12-cv-02026-AWI-JLT

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