Knickerbocker v. United States Department of Interior, Death Valley National Park, National Park Service
Filing
66
STIPULATION and ORDER 65 to Modify the Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 12/10/2018. Discovery Deadlines: Non-expert 3/1/2019; Expert 5/17/2019. Non-Dispositive Motion Deadlines: Filed by 5/21/2019; Hearing by 6/18/2019. Dispositive Motion Deadlines: Filed by 7/2/2019; Hearing by 8/6/2019. Pretrial Conference continued to 10/21/2019 at 02:30 PM in Courtroom 5 (DAD) before District Judge Dale A. Drozd. Jury Trial continued to 12/17/2019 at 01:00 PM in Courtroom 5 (DAD) before District Judge Dale A. Drozd. (Hall, S)
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1 Richard L. Knickerbocker, Esq. SB#035646
Knickerbocker Law Firm
2 2425 Olympic Boulevard
Suite 4000W
3 Santa Monica, California 90404
Telephone 310 260-9060
4 Facsimile 310 260-9063
Email knicklaw@gmail.com
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Attorneys for Plaintiff
6 ISSAM ELIE KNICKERBOCKER
7 MCGREGOR W. SCOTT
United States Attorney
8 JOSEPH B. FRUEH
Assistant United States Attorney
9 501 I Street, Suite 10-100
Sacramento, CA 95814
10 E-mail:
joseph.frueh@usdoj.gov
Telephone: (916) 554-2702
11 Facsimile: (916) 554-2900
12 Attorneys for Defendants
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IN THE UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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ISSAM ELIE KNICKERBOCKER,
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Plaintiff,
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v.
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UNITED STATES OF AMERICA; UNITED
STATES DEPARTMENT OF INTERIOR,
NATIONAL PARK SERVICE, DEATH
VALLEY NATIONAL PARK; NICOLE
GRUVER; BRYAN DREW; and DOES 3–25,
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Defendants.
Case No. 1:16-cv-01811-DAD-JLT
STIPULATION AND PROPOSED ORDER
TO MODIFY SCHEDULING ORDER
(Doc. 65)
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STIPULATION AND PROPOSED ORDER TO MODIFY SCHEDULING ORDER
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IT IS HEREBY STIPULATED, by and between the parties through their undersigned counsel,
3 that the Scheduling Order (ECF No. 59) be modified as follows:
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Current Deadline
Proposed Deadline
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Non-Expert Discovery Cutoff
January 31, 2019
March 1, 2019
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Initial Expert Disclosures
February 15, 2019
March 15, 2019
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Rebuttal Expert Disclosures
March 15, 2019
April 19, 2019
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Expert Discovery Cutoff
April 12, 2019
May 17, 2019
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Non-Dispositive Motion Filing
April 23, 2019
May 21, 2019
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Non-Dispositive Motion Hearing
May 21, 2019
June 18, 2019
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Dispositive Motion Filing
June 4, 2019
July 2, 2019
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Dispositive Motion Hearing
July 16, 2019
August 6, 2019
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Settlement Conference
September 6, 2019
September 6, 2019
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Pretrial Conference
September 23, 2019
October 21, 2019
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Trial
November 19, 2019
December 10, 2019
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The reasons for this stipulation are as follows:
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1.
Plaintiff’s counsel’s home and law practice were impacted by the Woolsey Fire, which
18 burned approximately 97,000 acres in Los Angeles and Ventura Counties from November 8 to 16, 2018.
19 To date, he and his family remain evacuated due to ongoing clean-up activities and utility outages. His
20 files and records are located in Malibu, California, and have been inaccessible.
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2.
Defendants’ counsel substituted into this case on November 7, 2018. Defendants’ prior
22 counsel of record left the United States Attorney’s Office on November 30, 2018. Defendants’ new
23 counsel was required to spend significant time in November reviewing and analyzing the case file.
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STIPULATION AND PROPOSED ORDER
TO MODIFY SCHEDULING ORDER
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3.
The foregoing developments have delayed the completion of fact discovery in this action,
2 and the parties believe there is good cause to continue most of the remaining deadlines in the Scheduling
3 Order by approximately 30 days, as set forth above.
4 Dated: December 6, 2018
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KNICKERBOCKER LAW FIRM
By:
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/s Richard L. Knickerbocker (authorized 12/6/2018)
Richard L. Knickerbocker
Attorney for Plaintiff
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8 Dated: December 7, 2018
MCGREGOR W. SCOTT
United States Attorney
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By:
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/s Joseph B. Frueh
JOSEPH B. FRUEH
Assistant United States Attorney
Attorneys for Defendants
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ORDER
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Based upon the stipulation, the Court ORDERS the case schedule to be amended as follows:
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1.
Non-Expert Discovery Cutoff:
March 1, 2019
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Expert Disclosures:
March 15, 2019
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Rebuttal Expert Disclosures:
April 19, 2019
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Expert Discovery Cutoff:
May 17, 2019
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Non-Dispositive Motion Filing:
May 21, 2019
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Non-Dispositive Motion Hearing:
June 18, 2019
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Dispositive Motion Filing:
July 2, 2019
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Dispositive Motion Hearing:
August 6, 2019
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Pretrial Conference:
October 21, 2019, 2:30 p.m.
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STIPULATION AND PROPOSED ORDER
TO MODIFY SCHEDULING ORDER
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10.
December 17, 20191, 1:00 p.m.
Trial:
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IT IS SO ORDERED.
Dated:
December 10, 2018
/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE
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The stipulation failed to allow for eight weeks between the pretrial conference and the trial.
STIPULATION AND PROPOSED ORDER
TO MODIFY SCHEDULING ORDER
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