Fajardo v. City of Bakersfield et al

Filing 47

STIPULATION and ORDER 46 to Modify the Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 8/22/2019. Expert Discovery Cutoff 11/14/2019. Non-Dispositive Motion Deadlines: Filed by 9/17/2019; Hearing by 10/15/2019. Dispositive Motion Deadlines: Filed by 10/28/2019; Hearing by 12/13/2019. (Hall, S)

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Michael G. Marderosian, No. 77296
Heather S. Cohen, No. 263093
MARDEROSIAN & COHEN
1260 Fulton Street
Fresno, CA 93721
Telephone: [phone]
Facsimile: [phone]
Virginia Gennaro, No. 138877
City Attorney
CITY OF BAKERSFIELD
1501 Truxtun Avenue
Bakersfield, CA 93301
Telephone: [phone]
Facsimile: [phone]

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Attorneys for: Defendants CITY OF BAKERSFIELD, JUAN OROZCO, and LINDY DEGEARE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GILBERTO FAJARDO,

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Plaintiff,
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vs.
CITY OF BAKERSFIELD; JUAN
OROZCO; LINDY DEGEARE; and
DOES 1 THROUGH 10, inclusive,

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Defendants.

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Case No. 1:16-CV-00699-JLT
STIPULATION TO MODIFY THE
SCHEDULING ORDER [DKT. NO. 36];
[PROPOSED] ORDER THEREON
(Doc. 36)

RECITALS

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1.

WHEREAS, on May 30, 2018 this Court issued its Scheduling Order [Dkt. No. 36].

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2.

WHEREAS, on May 16, 2019 the Parties filed a Stipulation to Modify the Scheduling Order

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[Dkt. No. 39] to extend the time for expert disclosures and expert discovery cutoff and the Court issued an

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Order granting same on May 17, 2019 [Dkt. No. 40].

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WHEREAS, due to the number of expert witnesses in this catastrophic injury case who are

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dependent on one another in terms of their analysis and given the volume of materials and complicated facts

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of the case, the Parties require additional time to prepare their expert disclosures and conduct expert discovery

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and request that the deadlines be extended by three weeks as set forth in the below Stipulation.

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4.

WHEREAS, the requested extension will not in any way affect the Pretrial Conference date

of December 16, 2019, or the Trial date of February 10, 2020.
STIPULATION

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IT IS HEREBY STIPULATED by and between the Parties hereto through their respective
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attorneys of record that the following deadlines be continued as follows:
Deadline

Current Date

Requested Date

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Non-Dispositive Motions

August 27, 2019

September 17, 2019

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Expert Disclosures

August 28, 2019

September 18, 2019

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Hearing on Non-Dispositive Motions

September 24, 2019

October 15, 2019

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Rebuttal Expert Disclosures

September 30, 2019

October 21, 2019

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Dispositive Motions

October 7, 2019

October 28, 2019

Expert Discovery Cutoff

October 14, 2019

November 4, 2019

Hearing on Dispositive Motions

November 18, 2019

December 13, 2019

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Dated: August 22, 2019

MARDEROSIAN & COHEN

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/s/ Michael G. Marderosian
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By:______________________________
Michael G. Marderosian,
Attorneys for Defendants

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Dated: August 22, 2019

LAW OFFICES OF DALE K. GALIPO
/s/ Dale K. Galipo

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By:______________________________
Dale K. Galipo,
Attorneys for Plaintiff

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Dated: August 22, 2019

CHAIN COHN STILES
/s/ David K. Cohn

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By:______________________________
David K. Cohn,

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Attorneys for Plaintiff
IT IS SO ORDERED.

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Dated:

August 22, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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