Lopez v. DeVry University, Inc. et al
Filing
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Stipulation to Continue Expert Discovery Cutoff and Plaintiff's Motion to Compel Supplemental Discovery Responses Deadline; Order, signed by Magistrate Judge Michael J. Seng on 07/03/2014. (Yu, L)
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SEYFARTH SHAW LLP
Mark P. Grajski (SBN 178050)
Email: mgrajski@seyfarth.com
400 Capitol Mall, Suite 2350
Sacramento, California 95814-4428
Telephone:
(916) 448-0159
Facsimile:
(916) 558-4839
Attorney for Defendant
DEVRY UNIVERSITY, INC.
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LAW OFFICES OF PARNELL FOX
Parnell Fox (SBN 186519)
Email: parnell@parnellfoxlaw.com
4908 Lakewood Court
Visalia, California 93291
Telephone:
(310) 890-0435
Facsimile:
(310) 776-6918
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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LORENA LOPEZ,
Plaintiff,
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Case No. 1:13-CV-00844-AWI-MJS
STIPULATION TO CONTINUE EXPERT
DISCOVERY CUTOFF AND PLAINTIFF’S
MOTION TO COMPEL SUPPLEMENTAL
DISCOVERY RESPONSES DEADLINE;
ORDER
v.
DEVRY UNIVERSITY, INC.; an Illinois
corporation and DOES 1-100, inclusive,
Date Action Filed: March 21, 2013
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Defendants.
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DeVry University (“Defendant”) and Lorena Lopez (“Plaintiff”) (collectively referred to herein
as the “Parties”), by and through their undersigned counsel, hereby stipulate and agree as follows:
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1.
WHEREAS, the deadline to complete expert discovery is July 7, 2014.
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2.
WHEREAS, the deadline to file discovery motions is July 7, 2014.
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3.
WHEREAS, the Parties have worked diligently to coordinate and schedule the
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depositions of two non-retained healthcare providers of Plaintiff identified in Plaintiff’s Expert Witness
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Disclosure, Isabel C. Amancio, LMFT, 113 Church Street, #418, Visalia, California, and Shyam
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Bhaskar, MD, 231, W. Noble Avenue, Visalia, California 93277;
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STIPULATION TO CONTINUE EXPERT DISCOVERY DEADLINE; [PROPOSED] ORDER
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4.
WHEREAS, Defendant served subpoenas for deposition testimony and production of
documents on Ms. Amancio and Dr. Bhaskar for late June 2014 depositions;
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WHEREAS, Dr. Bhaskar advised the Parties that he was completely unavailable prior to
this time and, further, that he would out of the country until August 2014.
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WHEREAS, the Parties further believe that the most cost efficient approach to expert
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depositions in this case would be to take both in a single day, particularly because of Defendant’s need
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to travel from Sacramento to Visalia;
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7.
WHEREAS, the Parties have also worked diligently to meet and confer on written
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discovery propounded by Plaintiff, including two sets of requests for production of documents and
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interrogatories. Defendant anticipates supplemental responses will be served by July 15, 2014 and
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thereafter Plaintiff will need additional time to review and determine if a motion to compel further
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responses is necessary.
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8.
WHEREAS, the parties have agreed that discovery shall remain open to September 8,
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2014 only for the following: (1) Defendant to depose Plaintiff's healthcare experts Shyam Bhaskar, M.D.
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and Isabel Amancio, MFT; and (2) Defendant to prepare and serve supplemental discovery responses
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(per Plaintiff's February 3, 2014 and Defendant's February 21, 2014 meet and confer correspondence),
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and Plaintiff to move to compel such supplemental responses if necessary.
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9.
WHEREAS, extending the deadline for expert discovery and Plaintiff’s motion to compel
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supplemental written discovery responses will not result in a change to subsequent deadlines regarding
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the January 6, 2015 trial date.
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NOW THEREFORE, all Parties hereto stipulate and agree that the Court may enter an Order
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extending discovery to September 8, 2014 for: (1) Defendant to depose Plaintiff's healthcare experts
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Shyam Bhaskar, M.D. and Isabel Amancio, MFT; and (2) Defendant to prepare and serve supplemental
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discovery responses (per Plaintiff's February 3, 2014 and Defendant's February 21, 2014 meet and
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confer correspondence) and Plaintiff to move to compel such supplemental responses if necessary.
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Plaintiff reserves the right to file a motion and seek leave for additional discovery subject to the Court’s
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approval and good cause shown.
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STIPULATION TO CONTINUE EXPERT DISCOVERY DEADLINE; [PROPOSED] ORDER
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: July 2, 2014
Respectfully submitted,
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SEYFARTH SHAW LLP
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By: /s/ Mark P. Grajski
Mark P. Grajski
Attorney for Defendant
DEVRY UNIVERSITY, INC.
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DATED: July 2, 2014
LAW OFFICES OF PARNELL FOX
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By: /s/ Parnell Fox
Parnell Fox
Attorneys for Plaintiff
LORENA LOPEZ
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ORDER
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Good cause appearing, the above Stipulation is accepted and adopted as the Order of
this Court.
IT IS SO ORDERED.
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Dated:
July 2, 2014
/s/
Michael J. Seng
UNITED STATES MAGISTRATE JUDGE
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STIPULATION TO CONTINUE EXPERT DISCOVERY DEADLINE; [PROPOSED] ORDER
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