Holcomb v. Ramar et al

Filing 41

STIPULATION and ORDER for CONTINUANCE OF DISCOVERY CUT-OFF AND EXPERT DISCLOSURE. The scheduled is modified as follows: Non-Expert Discovery deadline reset to 7/1/2015; Expert Disclosure deadline reset to 7/13/2015; Rebuttal Expert Disclosure deadline reset to 7/24/2015. No other scheduling deadlines are modified. Order signed by Magistrate Judge Sheila K. Oberto on 5/14/2015. (Timken, A)

1
2
3
4
5
6
7
UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9
10 HARVEY HOLCOMB,

Case No: 13-cv-01102-AWI-SKO

Plaintiff,

11
12 v.

13 JERRY RAMAR, a Modesto police officer;
OFFICER KROUTIL, a Modesto police officer;
14 OFFICER COX, a Modesto police officer;
OFFICER BOTTOMS, a Modesto police
officer; OFFICER CICCARELLI, a Modesto
15 police officer; J. CHANDLER, a Modesto
police officer; JOHN DOE and RICHARD
16 ROE, Modesto police officers, the true names
and exact numbers of whom are unknown at this
17 time; CITY OF MODESTO, a municipal
corporation,
18
Defendants.
19

STIPULATION REQUESTING BRIEF
CONTINUANCE OF DISCOVERY CUTOFF AND EXPERT DISCLOSURE ONLY;
ORDER THEREON

20
21
22
23
24
25
26
27
28
2440306.1

STIPULATION RE DISCOVERY CUT-OFF AND EXPERT DISCLOSURE; ORDER THEREON
[13-cv-01102-AWI-SKO]

1
2

PARTIES
The parties to this Stipulation are Plaintiff HARVEY HOLCOMB (“Plaintiff” or

3 “Holcomb”) and Defendants CITY OF MODESTO, JERRY RAMAR, JAIME COX, BEN
4 KROUTIL, JOSEPH BOTTOMS, TOM CICCARELLI and JEANNE CHANDLER
5 (“Defendants”), collectively, (“Parties”).
6

RECITALS

7

WHEREAS, the Parties have been working cooperatively to complete the necessary

8 discovery by the current deadline of June 12, 2016. But, intervening trial that begins on June 9,
9 2015, will make that difficult. Accordingly, the parties are requesting a brief continuance of the
10 discovery cut-off from June 16, 2015 to July 1, 2015. The parties are also requesting an extension
11 of the current deadline for expert disclosure from June 26, 2015 to July 13, 2015. The Parties are
12 not requesting that any other deadlines be continued and do not believe that the brief extensions
13 requested will interfere in anyway with the current deadline for filing dispositive motions or the
14 trial date of January 12, 2016.
15
16

STIPULATION

17

WHEREFORE, the Parties agree and stipulate as follows:

18

1.

The Parties respectfully request that the Court continue the discovery cut-off in this

19 matter from June 12, 2015 to July 1, 2015.
20

2.

The parties are also requesting an extension of the current deadline for expert

21 disclosure from June 26, 2015 to July 13, 2015.
22

IT IS SO STIPULATED:

23
24 DATED: May 14, 2015

MEYERS, NAVE, RIBACK, SILVER & WILSON

25
26

By:

27
28

/S/ Blake P. Loebs
Blake P. Loebs
Kevin P. McLaughlin
Attorney for Defendants

1
STIPULATION RE DISCOVERY CUT-OFF AND EXPERT DISCLOSURE; ORDER THEREON
[13-cv-01102-AWI-SKO]

2440306.1

1
DATED: May 14, 2015

LAW OFFICES OF ANTHONY BOSKOVICH

2
3

By:

4
5
6

/S/ Anthony Boskovich
Anthony Boskovich
Attorney for Plaintiff
HARVEY HOLCOMB
ORDER

7
The parties have requested a schedule modification to continue the non-expert discovery

8

9 deadline and the deadline to disclose experts. The parties have not requested a modification to the
10 rebuttal expert disclosure deadline, which would occur, under the proposed schedule, before the
11 modified deadline to disclose experts. As such, the Court modifies the schedule pursuant to the
12 parties' stipulation and further modifies the deadline for rebuttal expert disclosure. The schedule is
13 modified as follows:
14
Event

15

Modified Deadline

Current Deadline

16 1.

Non-Expert Discovery

July 1, 2015

June 12, 2015

17 2.

Expert Disclosure

July 13, 2015

June 26, 2015

Rebuttal Expert Disclosure

July 24, 2015

July 10, 2015

18

3.

19
20 No other scheduling deadlines are modified.
21
22
23

IT IS SO ORDERED.
Dated:

May 14, 2015

/s/ Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28

2
STIPULATION RE DISCOVERY CUT-OFF AND EXPERT DISCLOSURE; ORDER THEREON
[13-cv-01102-AWI-SKO]

2440306.1