D.G., et al v. County of Kern

Filing 25

JOINT STIPULATION FOR A SHORT DISCOVERY EXTENSION signed by District Judge John A. Mendez on April 12, 2016 ORDERING the Scheduling Conference Order shall be amended to provide for the following deadlines extensions of two weeks: a) Rule 26 Designation of Expert Witnesses is extended to May 20, 2016; b) Rule 26 Designation of Supplemental Experts is extended to May 27, 2016; and c) Extend the "all discovery" deadline date is extended for two weeks to July 15, 2016. (Becknal, R)

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THERESA A. GOLDNER, COUNTY COUNSEL
By: ANDREW C. THOMSON, DEPUTY (SBN 149057)
KATHLEEN RIVERA (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 Deputy Reed

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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)
D.G., a minor, by and through his
)
guardian ad litem, Denise Bonilla,
individually and as successor-in-interest )
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to David Garcia, deceased; D.E.G., a
minor, by and through her guardian ad )
litem, Denise Bonilla, individually and )
as successor-in-interest to David Garcia, )
)
deceased; G.D., a minor, by and
through her guardian ad litem, Denise )
Bonilla, individually and as successor- )
in-interest to David Garcia, deceased; )
)
RAMONA RAMIREZ NUNEZ,
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individually;
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Plaintiffs,
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vs.
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COUNTY OF KERN; DOES 1
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THROUGH 10;
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Defendants.
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CASE NO. 1:15-CV-00760 JAM-JLT
JOINT STIPULATION FOR A SHORT
DISCOVERY EXTENSION

[ALL PARTIES REQUEST A JURY]

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COME NOW the Parties in this matter, and present this Joint Stipulation for a Short
Discovery Extension.

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Plaintiffs, D.G., a minor, by and through his guardian ad litem, Denise Bonilla; D.E.G.,

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a minor, by and through her guardian ad litem, Denise Bonilla; G.D., a minor, by and through

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her guardian ad litem, Denise Bonilla; and Ramona Ramirez Nunez, (hereinafter collectively

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JOINT STIPULATION FOR A SHORT DISCOVERY EXTENSION
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“Plaintiffs”) are Jointly represented by Matthew C. Clark and Neil K. Gehlawat of Chain-

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Cohn-Stiles, and Dale K. Galipo of the Law Offices of Dale K. Galipo.

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Defendants, County of Kern (hereinafter “County”) and Deputy Robert Reed

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(hereinafter “Reed”), (hereinafter collectively “Defendants”) are represented by Andrew C.

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Thomson and Kathleen Rivera, Office of Kern County Counsel.

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Plaintiff and Defendants are hereinafter collectively referred to as the “Parties.”

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IT IS HEREBY STIPULATED AND AGREED TO, by and between the Parties, through

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their respective counsel of record, that an Order be entered allowing the Parties the following

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extensions of two weeks: a) Rule 26 Designation of Expert Witnesses to May 20, 2016; b) Rule

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26 Designation of Supplemental Experts to May 27, 2016; and c) Extend the “all discovery”

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deadline date for two weeks to July 15, 2016. These proposed dates are each two weeks later

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than the deadlines set forth in the Scheduling Order.

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1.

The Parties have repeatedly met and conferred regarding discovery and expert

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witness discovery issues in an effort to informally resolve discovery and expert issues,

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including deposition scheduling and designation concerns.

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2.

The Parties have been able to schedule the deposition of all witnesses, other

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than those identified below, within the deadlines established by the Court in coordination with

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the Rule 26 Designation of Experts deadline.

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3.

Plaintiffs have indicated a desire to take the deposition of the Coroner’s

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Pathologist but due to schedule conflicts, the Parties have been unable to schedule the

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deposition.

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4.

Defendants have noticed the depositions of Plaintiffs, and have requested

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deposition availability information, but due to scheduling conflicts, the Parties have been

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unable to schedule the depositions.

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5.

In the spirit of civility, cooperation and good faith litigation, neither party has

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unilaterally scheduled depositions that are in conflict with the schedule of opposing counsel or

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the deponent.

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JOINT STIPULATION FOR A SHORT DISCOVERY EXTENSION
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6.

As a result of the need to take the aforementioned depositions, the Parties are

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concerned that their experts will not have an opportunity to review, analyze and include all of

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the deposition information in the expert’s Rule 26 Expert Designation Report.

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7.

In an effort to ensure that all experts have the opportunity to review all

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depositions prior to submitting their reports, the Parties request the following extensions of two

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weeks:

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a) Rule 26 Designation of Expert Witnesses to May 20, 2016;

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b) Rule 26 Designation of Supplemental Experts to May 27, 2016; and

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c) Extend the “all discovery” deadline date for two weeks to July 15, 2016.

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The Parties are informed and believe that the foregoing will not adversely affect

the remainder of the dates set forth in the Scheduling Conference Order.
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The Parties respectfully request the Court’s consideration of this request.

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THEREFORE, IT IS HEREBY STIPULATED:

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The Scheduling Conference Order shall be amended to provide for the following
deadlines extensions of two weeks:

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a) Rule 26 Designation of Expert Witnesses is extended to May 20, 2016;

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b) Rule 26 Designation of Supplemental Experts is extended to May 27, 2016; and

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c) Extend the “all discovery” deadline date is extended for two weeks to July 15, 2016.

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Dated: April 11, 2016

CHAIN-COHN-STILES

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By /s/ Neil K. Gehlawat
Matthew C. Clark
Neil K. Gehlawat
Attorneys for Plaintiffs 

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JOINT STIPULATION FOR A SHORT DISCOVERY EXTENSION
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Dated: April 11, 2016

THERESA A. GOLDNER, COUNTY COUNSEL

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By /s/ Andrew C. Thomson
Andrew C. Thomson, Deputy
Attorneys for Defendants County of
Kern and Deputy Reed

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IT IS SO ORDERED.

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Dated: April 12, 2016

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/s/ John A. Mendez________________________
JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

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#22M1751

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JOINT STIPULATION FOR A SHORT DISCOVERY EXTENSION
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