Ghuman v. United States of America

Filing 12

STIPULATION and ORDER 11 to Continue Settlement Conference and Discovery Deadlines, signed by Magistrate Judge Jennifer L. Thurston on 6/19/2017. Settlement Conference CONTINUED to 1/8/2018 at 09:30 AM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. (Hall, S)

1 PHILLIP A. TALBERT
United States Attorney
2 VICTORIA L. BOESCH
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
5 [e-mail]
6 Attorneys for the United States
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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KULVEER K. GHUMAN,
CASE NO. 1:16-CV-1443-DAD-JLT
Plaintiff,

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v.
UNITED STATES OF AMERICA
Defendant.

STIPULATION AND [PROPOSED] ORDER
TO CONTINUE SETTLEMENT
CONFERENCE AND DISCOVERY
DEADLINES
(Doc. 11)

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Plaintiff Kulveer K. Ghuman and Defendant United States of America respectfully request that

17 the Court continue the settlement conference currently scheduled for August 4, 2017 at 1:30 p.m. to
18 September 8, 2017. This will give the parties an opportunity to finish some key discovery that will
19 render settlement discussions more productive. Rescheduling the settlement conference for this date
20 would make Plaintiff’s written itemization of damages and meaningful settlement demand that includes
21 a brief explanation of why such a settlement is appropriate due to Defendant on August 18, 2017.
22 Defendant’s response of either acceptance or a meaningful counteroffer that includes a brief explanation
23 of why such a settlement is appropriate would be due to Plaintiff on August 25, 2017. The parties
24 would have to submit confidential settlement conference statements by email to Judge Thurston by
25 September 1, 2017. Defendant also requests that the Court permit agency counsel representing the
26 Department of Health and Human Services, who is located in the District of Columbia, to attend the
27 settlement conference by telephone.
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STIPULATION & [PROPOSED] ORDER TO CONTINUE SETTLEMENT CONFERENCE & DISCOVERY DEADLINES

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Because of scheduling conflicts, the parties also respectfully request the following minor

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2 adjustments to the case schedule. These adjustments will not affect the trial and pretrial dates set by the
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Event

Current Date

Proposed New Date

July 28, 2017

August 11, 2017

August 11, 2017

August 25, 2017

September 8, 2017

September 22, 2017

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6 Fact Discovery Cut Off
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Plaintiff Expert Disclosure

9 Defendant Expert Disclosure
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Respectfully submitted,
PHILLIP A. TALBERT
United States Attorney

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14 Dated: June 15, 2017
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By:

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/s/ Victoria L. Boesch
VICTORIA L. BOESCH
Assistant United States Attorney
Attorneys for the United States
LEVY LAW FIRM

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18 Dated: June 15, 2017
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By:

/s/ Dane Levy (authorized 6/15/17)
DANE LEVY
Dane Levy, Esq.
Bjorn Burlin, Esq.
Levy Law Firm
Attorneys for Plaintiff Kulveer K. Ghuman
ORDER

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The stipulation to amend the case schedule is GRANTED in PART as follows:

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1.

All non-expert discovery SHALL be completed no later than August 11, 2017;

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2.

Plaintiff SHALL disclose his experts no later than August 25, 2017 and Defendant

25 SHALL disclose its experts no later than September 22, 2017. Plaintiff SHALL disclose rebuttal
26 experts, if any, no later than October 13, 2017;
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3.
The settlement conference is CONTINUED to January 8, 2018 at 9:30 a.m. The
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STIPULATION & [PROPOSED] ORDER TO CONTINUE SETTLEMENT CONFERENCE & DISCOVERY DEADLINES

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1 deadlines set forth in the scheduling order (Doc. 8 at 6-7) remain in effect.
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IT IS SO ORDERED.
Dated:

June 19, 2017

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION & [PROPOSED] ORDER TO CONTINUE SETTLEMENT CONFERENCE & DISCOVERY DEADLINES

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