Avila et al v. State of California et al

Filing 38

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/17/17 ORDERING that the Expert Disclosure date is EXTENDED from 2/17/17 to 3/17/2017. The Supplemental Expert Disclosure date is EXTENDED from 3/17/17 to 4/17/2017. Discovery due date is EXTENDED from 4/14/17 to 4/28/2017. The parties agree that all other deadlines will remain in place as set out in the Scheduling Order, including that Trial remain SET on 9/11/17.(Mena-Sanchez, L)

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Stephen R. Cornwell, CA Bar #40737
CORNWELL & SAMPLE, LLP
Attorneys at Law
7045 N. Fruit Avenue
Fresno, CA 93711-0761
Telephone: [phone]
Facsimile: [phone] 

(SPACE BELOW FOR FILING STAMP ONLY)

Attorneys for Plaintiffs MELINDA AVILA, GRETEL LORENZO, ALFREDO
LORENZO, and JOSE LORENZO

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MELINDA AVILA, GRETEL LORENZO,)
ALFREDO LORENZO, and JOSE
)
LORENZO,
)
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Plaintiffs,
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)
v.
)
)
STATE OF CALIFORNIA; COUNTY OF )
MADERA; RICHARD GONZALES;
)
PAUL VARNER; GUY RICH and DOES )
3 through 100, inclusive,
)
)
Defendants.
)
)

CASE NO.: 1:15-cv-00996-JAM-EPG
[Removed from Fresno County Superior
Court, Civil Case No. MCV067084]
STIPULATION TO CONTINUE
DATES FOR DESIGNATION OF
EXPERTS; ORDER
FINAL PRE-TRIAL: August 4, 2017
TRIAL: September 11, 2017

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CORNWELL & SAMPLE LLP
7045 N. Fruit Avenue
Fresno, CA 93711

This stipulation to extend current expert disclosure and discovery deadlines is
made by and between counsel for Plaintiffs Melinda Avila, Gretel Lorenzo, Alfredo
Lorenzo and Jose Lorenzo and counsel for Defendants State of California, County of
Madera, Richard Gonzales and Paul Varner.
Recitals
The parties jointly agree that to facilitate and complete full discovery in this
case, the expert disclosure and expert discovery deadlines currently set for the in the
Court’s Pre-Trial Scheduling Order (ECF No. 31) should be extended. Such extension will
have no effect on the trial date in this case.

STIPULATION TO CONTINUE DATES FOR DESIGNATION OF EXPERTS; [PROPOSED] ORDER
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Whereas, the parties are engaged in discovery now and find it in their mutual

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best interests or are otherwise agreeable to modify the dates for various tasks to be

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accomplished and wish to modify those dates to accommodate scheduling.
STIPULATION

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Now, THEREFORE, the parties do hereby stipulate and propose the
following extended dates, by and through their counsel as follows:
1. The original Expert Disclosure was February 17, 2017. The parties agree to
disclose experts on March 17, 2017.
2. The original Supplemental Expert Disclosure was March 17, 2017. The

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parties agree to extend the date for Supplemental Expert Disclosure to April

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17, 2017.

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3. The original deadline for completing discovery was April 14, 2017. The
parties agree discovery will close on April 28, 2017.

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4. The parties agree that all other deadlines will remain in place as set out in the

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Scheduling Order, including that Trial remain set on September 11, 2017.

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DATED: February _____, 2017.

CORNWELL & SAMPLE, LLP

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By:__________________________________
Stephen R. Cornwell
Attorneys for Plaintiffs
MELINDA AVILA, GRETEL LORENZO,
ALFREDO LORENZO, and JOSE LORENZO

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DATED: February _____, 2017.

COTA COLE LLP

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CORNWELL & SAMPLE LLP
7045 N. Fruit Avenue
Fresno, CA 93711

By:__________________________________
Carolyn J. Frank
Attorneys for Defendants
COUNTY OF MADERA and RICHARD
GONZALES
STIPULATION TO CONTINUE DATES FOR DESIGNATION OF EXPERTS; [PROPOSED] ORDER
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ATTORNEY GENERAL OF
CALIFORNIA

DATED: February _____, 2017.

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By:__________________________________
Catherine Woodbridge
Attorneys for Defendants
STATE OF CALIFORNIA by and through
CALIFORNIA HIGHWAY PATROL and
PAUL VARNER

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ORDER
The Court hereby adopts the parties stipulation set for the above.
IT IS SO ORDERED.

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Dated: 2/17/2017

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

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F:\Cases\AVILA.Melinda\PLEADINGS\STIP to CONTINUE.EXPERT.DISCLOSURE.doc

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CORNWELL & SAMPLE LLP
7045 N. Fruit Avenue
Fresno, CA 93711

STIPULATION TO CONTINUE DATES FOR DESIGNATION OF EXPERTS; [PROPOSED] ORDER
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