Martinez v. City of Clovis, et al.

Filing 57

STIPULATION and ORDER signed by District Judge John A. Mendez on 8/12/16 ORDERING that the current discovery deadlines should be EXTENDED as follows: (a) Non-expert Discovery shall be completed by 3/15/17; (b) Expert witness shall be disclosed by 3 /15/17; (c) Supplemental expert witnesses shall be disclosed by 3/29/17; and (d) Expert Discovery shall be completed by 5/26/17. The current trial and pretrial deadlines should be EXENDED as follows: (a) Non-dispositive Motions shall be filed no la ter than 6/4/17; (b) Dispositive Motions shall be filed no later than 6/27/17 and noticed for hearing on 7/25/17 at 1:30 p.m.; (c) A joint pretrial statement shall be filed on or before 9/29/17; (d) a Pretrial Conference shall be held on 10/6/17 at 10:00 a.m.; and (e) Jury trial shall be set for 12/4/17 at 9:00 a.m.(Mena-Sanchez, L)

Kevin G. Little, SBN 149818
1 Michelle L. Tostenrude, SBN 290141
LAW OFFICE OF KEVIN G. LITTLE
2 Post Office Box 8656
Fresno, CA 93747
3 Phone Number: [phone]
Fax Number: [phone]
4 Email: [e-mail]
5 Attorneys for Plaintiff
DESIREE MARTINEZ
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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-0683 JAM MJS

DESIREE MARTINEZ,
Plaintiff,

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STIPULATION AND ORDER RE:
MODIFICATION OF DISCOVERY AND
CASE SCHEDULE

vs.
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KYLE PENNINGTON; KIM PENNINGTON;
14 CONNIE PENNINGTON; KRISTINA
HERSHBERGER; JESUS SANTILLAN;
15 CHANNON HIGH; THE CITY OF CLOVIS;
ANGELA YAMBUPAH; RALPH SALAZAR;
16 FRED SANDERS; THE CITY OF SANGER;
AND DOES 1 through 20,
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Defendants.
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TO THE HONORABLE COURT:
WHEREAS the pleadings remain unsettled, due to the pendency of a motion challenging the

22 plaintiff's Second Amended Complaint until the Court's ruling on August 9, 2016 (Dkt. No. 55), and
23 the current pending status of the moving defendants' responsive pleadings; and
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WHEREAS, the parties agree that the operative pleadings will define the scope of
discovery; and

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WHEREAS, the parties anticipate that the pleadings will be settled within the next 20 days,
in compliance with the Court's August 9, 2016 Order; and
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WHEREAS, all parties are in agreement that good cause exists for modification of the case

schedule based upon these factors,
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THE PARTIES HEREBY STIPULATE AS FOLLOWS:
The current discovery deadlines should be extended as follows: (a) Non-expert discovery

4 shall be completed by March 15, 2017; (b) Expert witness shall be disclosed by March 15, 2017; (c)
5 Supplemental expert witnesses shall be disclosed by March 29, 2017; and (d) Expert discovery shall
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be completed by May 26, 2017.
The current trial and pretrial deadlines should be extended as follows: (a) Non-dispositive

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motions shall be filed no later than June 4, 2017; (b) Dispositive motions shall be filed no later than

10 June 27, 2017 and noticed for hearing on July 25, 2017 at 1:30 p.m.; (c) A joint pretrial statement
11 shall be filed on or before September 29, 2017; (d) a pretrial conference shall be held on October 6,
12 2017 at 10:00 a.m.; and (e) Jury trial shall be set for December 4, 2017 at 9:00 a.m.
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IT IS SO STIPULATED.

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Date: August 10, 2016
Kevin G. Little
Law Office of Kevin G. Little
Attorneys for Plaintiff
Desiree Martinez

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Date: August 10, 2016

/s/ Yan Shrayberman
Yan Shrayberman
Attorney for Defendant
Kyle Pennington

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Date: August 10, 2016
/s/ John Phillips
John W. Phillips
Wild, Carter & Tipton
Attorneys for
Defendants Kim and
Connie Pennington

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Stipulation and Proposed Order

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Date: August 10, 2016

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/s/ Craig Smith
G. Craig Smith
Ferguson, Praet & Sherman
Attorneys for Defendants
City of Clovis, City of Sanger and
Kristina Hershberger, Jesus Santillan, Channon
High, Angela Yambupah, Ralph Salazar and
Fred Sanders

IT IS SO ORDERED AS MODIFIED ABOVE BY THE COURT:

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Dated: August 12, 2016
/s/ John A. Mendez____________
U. S. District Court Judge

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-3Stipulation and Proposed Order