Maria R., et al. v. William Nulick, et al.

Filing 33

STIPULATION and ORDER signed by District Judge John A. Mendez on 8/29/2016 ORDERING that all parties are to serve their disclosure of Expert Witness(es) by the close of business 11/18/2016; all parties are to serve the disclosure of their Supplemental Expert Witness(es) by the close of business on 12/2/2016. (Zignago, K.)

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Brian S. Kabateck, SBN 152054
Christopher B. Noyes, SBN 270094
Benjamin S. Hakimfar, SBN 287457
KABATECK BROWN KELLNER LLP
644 South Figueroa Street
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
Dana Alden Fox, SBN 119761
Michael S. Moss, SBN 211115
LEWIS BRISBOIS BISGAARD & SMITH LLP
633 West 5th Street, Suite 4000
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants Tulare County
Sheriff and County of Tulare
Gary L. Logan, SBN 90558
LEBEAU-THELEN LLP
50001 E Commercenter Dr., Suite 300
Bakersfield, California 93309
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant William Nulick

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MARIA R., an individual; KARI R., an
individual; VICKY P., an individual;
NATASHA P., an individual;

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CASE NO. 1:15-cv-01378 JAM EPG
Magistrate Judge Erica P. Grojean

STIPULATION AND ORDER TO
CONTINUE THE PRETRIAL EXPERT
WITNESS DISCLOSURE DEADLINE

Plaintiffs,
vs.

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WILLIAM NULICK, an individual;
TULARE COUNTY SHERIFF, a
California
governmental
entity;
COUNTY OF TULARE, a California
governmental entity; and DOES 1 to 50,
inclusive,
Defendants.

Action Filed: September 9, 2015
Trial Date: March 20, 2017

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4812-7001-3751.1

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STIPULATION AND [PROPOSED] ORDER

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WHEREAS, Plaintiffs MARIA R., KARI R., VICKY P., and NATASHA P.
(hereinafter “Plaintiffs”), and Defendants WILLIAM NULICK, COUNTY OF

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TULARE and TUALRE COUNTY SHERIFF (“Defendants”), by and through their

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undersigned attorneys, submitted their joint report on December 24, 2015, pursuant

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to Fed. R. Civ. P. 26(f), and this Court’s Order of September 10, 2015.
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WHEREAS, pursuant to this Court’s order of December 28, 2015, the parties

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are to disclose their Expert Witness(es) on September 9, 2016 and for all parties to

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disclose their Supplemental Expert Witness(es) on September 16, 2016;

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WHEREAS, plaintiff, Maria Rangel’s deposition was timely noticed for

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August 16, 2016 and was continued to September 9, 2016 at the request of counsel

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for the plaintiffs in consideration of a scheduling conflict on the part of Maria
Rangel;
IT IS HEREBY STIPULATED, pursuant to Local Rules 143 and 230(f), by

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and between Plaintiffs and Defendants, through their respective attorneys of records,

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that all parties are to serve their disclosure of Expert Witness(es) by the close of

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business November 18, 2016 and are to serve the disclosure of their Supplemental

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Expert Witness(es) by the close of business on December 2, 2016.

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4812-7001-3751.1

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STIPULATION AND [PROPOSED] ORDER

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DATED: August 26, 2016

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KABATECK BROWN KELLNER LLP
By: s/ Christopher B. Noyes
Attorneys for Plaintiffs

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DATED: August 26, 2016

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LEWIS BRISBOIS BISGAARD & SMITH LLP
By: s/ Michael S. Moss ________________
Dana Alden Fox
Michael S. Moss
Attorneys for Defendants Tulare County
Sheriff and County of Tulare

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DATED: August 26, 2016

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LEBEAU-THELEN LLP
By: s/ Gary L. bLogan___________________
Gary Logan
Attorneys for Defendants William Nulick

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4812-7001-3751.1

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STIPULATION AND [PROPOSED] ORDER

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ORDER

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Based upon the stipulation of the parties, IT IS HEREBY ORDERED, all

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parties are to serve their disclosure of Expert Witness(es) by the close of business

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November 18, 2016; all parties are to serve the disclosure of their Supplemental

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Expert Witness(es) by the close of business on December 2, 2016.

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Dated: 8/29/2016

/s/ John A. Mendez__________________
Judge of the United States District Court

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4812-7001-3751.1

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STIPULATION AND [PROPOSED] ORDER