Hernandez v. The GEO Group, Inc. et al

Filing 27

ORDER GRANTING 26 Stipulation to Amend Case Schedule, signed by Magistrate Judge Jennifer L. Thurston on 12/22/2016. Discovery Deadlines: Non-expert 2/28/2017; Expert 4/6/2017. Non-Dispositive Motion Deadlines: Filed by 3/13/2017; Hearing by 4/10/2017. (Hall, S)

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CARLOS JIMENEZ, Bar No. 227534
[e-mail]
JESSICA S. KANG, Bar No. 273221
[e-mail]
LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: 213.443.4299
Attorneys for Defendants
THE GEO GROUP, INC. dba GEO CALIFORNIA,
INC. and GEO CORRECTIONS AND
DETENTION, LLC

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JOSEPHINE HERNANDEZ,
Plaintiff,

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v.
THE GEO GROUP, INC. dba GEO
CALIFORNIA, INC., a Florida
corporation; GEO CORRECTIONS
AND DETENTION, LLC, a Florida
limited liability company; and DOES 1
through 20, inclusive,
Defendants.

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LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA
90071
213.443.4300

Firmwide:144553485.3 080853.1012

Case No. 1:15 cv 01813 - JLT
ASSIGNED FOR ALL PURPOSE TO
HON. JENNIFER L. THURSTON
JOINT STIPULATION RE
REQUEST TO CONTINUE
DISCOVERY AND EXPERT
DISCOVERY DATES
(DOC. 26)

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Plaintiff Josephine Hernandez and Defendant The GEO Group, Inc. d/b/a GEO

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California, Inc. and GEO Corrections and Detention, LLC (collectively, the “Parties”)

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by and through their respective counsel of record hereby stipulate and respectfully

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request the Court continue the discovery cut-off and expert discovery cut-off dates in

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the above-reference matter, as follows:

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WHEREAS, on September 7, 2016, pursuant to the stipulation of the Parties,

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the Court continued the date of trial to July 24, 2017, and set the deadline to complete

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non-expert discovery for January 26, 2017 and the deadline to complete expert

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discovery for March 6, 2017 (Dkt. 22);

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WHEREAS, the Court, on its own motion, continued the pretrial conference to

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July 14, 2017 and the trial to July 24, 2017, to accommodate the Court’s schedule

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(Dkt. 23.);

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WHEREAS, the Parties have experienced unexpected delays in discovery in
this matter largely due to an unexpected personnel matter with Defendant’s Counsel;

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WHEREAS, Defendants wish to take the depositions of Plaintiff’s alleged

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treating physicians for emotional distress allegedly suffered by Plaintiff; however, due

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to the upcoming holidays and unexpected delays stated above, the depositions may not

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be completed prior to January 26, 2017;

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WHEREAS, the Parties have agreed that Plaintiff will participate in an

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independent medical examination (“IME”), which is currently set for January 9, 2017;

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WHEREAS, the completion of the depositions of Plaintiff’s alleged treating

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physicians and the IME are necessary for the drafting and filing of Defendants’

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dispositive motion;

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WHEREAS, the prior case schedule set the deadline for the Parties to disclose

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rebuttal expert witnesses by March 17, 2017, which is after the deadline, March 6,

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2017, to complete expert discovery;

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WHEREAS, the Parties will not be prejudiced by a continuation of the
discovery and expert discovery cut-off dates in light of the continuation of trial;

LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA
90071
213.443.4300

2.
Firmwide:144553485.3 080853.1012

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THEREFORE, the Parties respectfully request that the Court continue the
current dates as follows:

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 Discovery cut-off date: February 28, 2017;

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 Expert Discovery cut-off date: April 6, 2017;

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 The Parties shall disclose their experts no later than March 3, 2017, and

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any rebuttal experts by March 17, 2017.

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 Non-Dispositive Motion Filing Deadline: March 13, 2017;

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 Non-Dispositive Motion Hearing Deadline: April 10, 2017.

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Dated: December 22, 2016

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/s/ Jessica S. Kang
CARLOS JIMENEZ
JESSICA S. KANG
LITTLER MENDELSON, P.C.
Attorneys for Defendants
THE GEO GROUP, INC. DBA GEO
CALIFORNIA, INC. AND
GEO CORRECTIONS AND DETENTION,
LLC

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Dated:

December 22, 2016

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/s/ Alis M Moon
ALLYSON K. THOMPSON
ALIS M. MOON
KRING & CHUNG, LLP
On Behalf of Plaintiff
JOSEPHINE HERNANDEZ

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ORDER

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The stipulation is GRANTED. The amended case schedule requires:

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1.

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All non-expert discovery SHALL be completed no later than February

28, 2017;
2.

All expert discovery SHALL be completed no later than April 6, 2017;

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LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA
90071
213.443.4300

3.
Firmwide:144553485.3 080853.1012

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3.

The Parties SHALL disclose their experts no later than March 3, 2017,

and any rebuttal experts by March 17, 2017;
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Any non-dispositive motion SHALL be filed no later than March 13,

2017 and heard no later than April 10, 2017.

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The Court does not contemplate receiving any further requests for

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amendment to the case schedule nor does it contemplate granting any further

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requests for amendment to the case schedule.

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IT IS SO ORDERED.
Dated:

December 22, 2016

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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LITTLER MENDELSON, P.C.
633 West 5th Street
63rd Floor
Los Angeles, CA
90071
213.443.4300

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Firmwide:144553485.3 080853.1012