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

Filing 27

STIPULATION AND ORDER signed by District Judge John A. Mendez on 5/4/2016 ORDERING all parties to designate expert witnesses by 6/17/2016 and to designate supplemental expert witnesses by 7/1/2016. (Michel, G.)

1 CHAIN | COHN | STILES
Matthew C. Clark, Esq. (SBN 218784) | [e-mail]
2 Neil K. Gehlawat, Esq. (SBN 289388) | [e-mail]
1731 Chester Avenue
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Bakersfield, CA 93301
[phone]
4 Telephone:
Facsimile:
[phone]
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LAW OFFICES OF DALE K. GALIPO
6 Dale K. Galipo, Esq. (SBN 144074) | [e-mail]
21800 Burbank Boulevard, Suite 310
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Woodland Hills, CA 91367
[phone]
8 Telephone:
Facsimile:
[phone]
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Attorneys for Plaintiffs
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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 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-ininterest to David Garcia, deceased;
RAMONA RAMIREZ NUNEZ,
individually,

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CASE NO. 1:15-CV-00760-JAM-JLT
STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER

Plaintiffs,

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v.

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COUNTY OF KERN; DOES 1 through 10,
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Defendants.

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WHEREAS, the deadline to disclose expert witnesses in this matter is May 20, 2016.

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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
[phone]

-1STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER

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WHEREAS, the deadline to disclose rebuttal expert witnesses in this matter is May 27,

2 2016.
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WHEREAS, counsel for all parties agree that additional liability depositions are required

4 to properly evaluate the liability issues in this matter and to form the expert opinions.
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THEREFORE, IT IS HEREBY STIPULATED by the parties, by and through their

6 attorneys of record that the scheduled date in this matter for the Rule 26 Designation of Expert
7 Witnesses may be modified from May 20, 2016 to June 17, 2016, and the Rule 26 Designation of
8 Supplemental Experts may be modified from May 27, 2016 to July 1, 2016.
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The parties all understand and agree that the proposed new dates are subject to

10 modification by the court.
11 DATED:

May 4, 2016

CHAIN | COHN | STILES

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/s/ Neil K. Gehlawat
BY: ______________________________
Matthew C. Clark
Neil K. Gehlawat
Attorney for Plaintiff

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DATED:

May 4, 2016

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THERESA A. GOLDNER, COUNTY COUNSEL

/s/ Andrew C. Thomson
BY: ______________________________
Andrew C. Thomson, Deputy
Attorney for Defendants, COUNTY OF KERN
And Deputy Reed

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ORDER

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IT IS SO ORDERED.

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DATED: 5/4/2016

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

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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
[phone]

-2STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER

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CHAIN | COHN | STILES
1731 CHESTER AVENUE
BAKERSFIELD, CA 93301
[phone]