Lee v. Kern County et al

Filing 40

STIPULATION and ORDER signed by District Judge John A. Mendez on 12/20/2016 ORDERING that the Scheduling Order is Augmented as follows: Expert Disclosure: 1/31/2017; and Supplemental Expert Disclosure: 2/7/2017. (Jackson, T)

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MARK L. NATIONS, INTERIM COUNTY COUNSEL
By: Kathleen Rivera, Deputy (SBN 211606)
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone [phone]
Fax [phone]
Attorneys for Defendants County of Kern,
and Carlos Sillas
JILL L. RYTHER
RYTHER LAW GROUP
8560 W. Sunset Blvd., Ste. 500
West Hollywood, CA 90069
Telephone [phone]
Fax [phone]
Attorneys for Plaintiff Bonnie Lee

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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) Case No.: 1:15-CV-00068 JAM JLT
)
) STIPULATION TO AUGMENT
Plaintiff,
) SCHEDULING ORDER
v.
)
)
COUNTY OF KERN, a public entity;
)
KERN COUNTY PROBATION
)
DEPARTMENT, a public entity; and
)
PROBATION OFFICER CARLOS
SILLAS, individually and in his official )
)
capacity,
)
)
Defendants.

TO THE HONORABLE COURT:
BONNIE LEE,

This stipulation is entered into by and between the plaintiff and the defendants,
by and through their respective counsel.
1.

Pursuant to the Court’s Scheduling Order (DOC 36), the parties have

completed written disclosures and propounded and responded to written discovery.
The parties have taken depositions.

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Stipulation to Augment the Scheduling Order, 1:15-CV-00068 JAM JLT

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2.

The deadline to complete expert witness disclosures is January 13,

3.

Despite the diligence of all counsel, the parties’ respective experts will

2017.

not be able to complete their expert disclosures by January 13, 2017.
4.

It would be in the best interest of the parties and judicial council if the

scheduling order is modified slightly to enable the parties additional time to complete
expert disclosure.
5.

At this time, the parties do not wish to augment the scheduling order with

regard to any other matters other than expert disclosure.
6.

This is the parties’ first request to augment the scheduling order.

7.

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Based on the foregoing, the parties seek leave to augment the

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scheduling order as follows:
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Expert Disclosure:

From January 13, 2017 to January 31, 2017

Supplemental Expert Disclosure: From January 20, 2017 to February 7, 2017
NOW THEREFORE, IT IS HEREBY STIPULATED by the parties, subject to
approval by this Court, that the Scheduling Order be augmented as set forth above.

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Dated: December 19, 2016

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MARK L. NATIONS, INTERIM COUNTY
COUNSEL

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_
By: /s/ Kathleen Rivera
Kathleen Rivera, Deputy
Attorney for Defendants
County of Kern and Carlos Sillas

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Dated: December 19, 2016

LAW OFFICE OF JILL L. RYTHER

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By: /s/ Jill L. Ryther
_
Jill L. Ryther
Attorney for Plaintiff Bonnie Lee

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(Proposed Order to follow on next page)

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Stipulation to Augment the Scheduling Order, 1:15-CV-00068 JAM JLT

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ORDER
PER STIPULATION OF COUNSEL, IT IS HEREBY ORDERED that the
Scheduling Order be Augmented as follows:

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Expert Disclosure:

January 31, 2017

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Supplemental Expert Disclosure:

February 7, 2017

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DATED: 12/20/2016

/s/ John A. Mendez____________
United States District Court Judge

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Stipulation to Augment the Scheduling Order, 1:15-CV-00068 JAM JLT