Kim Adams v. County of Kern et al

Filing 38

STIPULATION and ORDER 37 to Modify Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 6/24/2019. Discovery Deadlines: Non-Expert 9/3/2019; Expert 10/21/2019. Non-Dispositive Motion Deadlines: Filed by 11/4/2019; Hearing by 12/16/2019. (Hall, S)

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James D. Weakley, Esq.
Brande L. Gustafson, Esq.

Bar No. 082853
Bar No. 267130

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Weakley & Arendt
A Professional Corporation
1630 East Shaw Ave., Suite 176
Fresno, California 93710
Telephone: [phone]
Facsimile: [phone]

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[e-mail]
[e-mail]

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Attorneys for Defendant, Reyes Soberon, Jr.

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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KIM ADAMS, an individual,
Plaintiff,

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vs.

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COUNTY OF KERN; KERN COUNTY
PROBATION DEPARTMENT; DAVID M.
KUGE, an individual; REYES SOBERON,
JR., and individual; and DOES 1 through 50,
inclusive,

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Defendants.

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CASE NO. 1:17-cv-00464-JLT
STIPULATION AND [Proposed] ORDER
TO MODIFY SCHEDULING ORDER
(Doc. 464)

The parties, by and through their respective counsel, have stipulated to modify the
discovery deadlines and existing Scheduling Order (Doc. No. 36) as follows:

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Event/Deadline

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Non-Expert Discovery

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Stipulated New Date

Deadline

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Existing Date
July 3, 2019

September 3, 2019

Expert Witness Disclosure

July 17, 2019

September 10, 2019

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Rebuttal Witness Disclosure

August 14, 2019

October 1, 2019

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Expert Discovery Deadline

September 9, 2019

October 21, 2019

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Stipulation & [Proposed] Order to
Modify Scheduling Order

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November 4, 2019

October 21, 2019

December 16, 2019

November 4, 2019

No Change

December 16, 2019

No Change

February 3, 2020

No Change

Trial

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September 23, 2019

Pre-Trial Conference

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Non-Dispositive Motion

March 30, 2020

No Change

Deadline (Filing)
Non-Dispositive Motion
Deadline (Hearing)

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Dispositive Motion Deadline
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(Filing)
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Dispositive Motion Deadline
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(Hearing)
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The parties request an order modifying scheduling order. The parties have been

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cooperating in scheduling depositions in an effort to conclude non-expert discovery within the

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time frame set out in the current scheduling order. However, Plaintiff’s children and caretaker

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are either out of town due to an ill family member or have their own medical appointments that

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prevent them from being available for a deposition prior to the current deadline to complete

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non-expert discovery. Additionally, counsel for defendants County of Kern and David M. Kuge

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is scheduled for knee surgery on June 26, 2019 and will be unavailable during the following

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three to four weeks while recovering from the surgery and there is no one else in the office with

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knowledge of this case that would be able to step in and take the remaining depositions.

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The parties believe these there is good cause for the above proposed changes to the

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discovery deadlines, which would allow the parties to keep the currently scheduled trial date.

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Respectfully Submitted,

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DATED: June 20, 2019

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WEAKLEY & ARENDT
A PROFESSIONAL CORPORATION
/s/ Brande L. Gustafson
James D. Weakley
Brande L. Gustafson
Attorneys for Defendant, Reyes Soberon, Jr.

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Stipulation & [Proposed] Order to
Modify Scheduling Order

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DATED: June 21, 2019

MARGO A. RAISON,
KERN COUNTY COUNSEL

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/s/ Marshall S. Fontes (As authorized on 6/21/19)
Marshall S. Fontes, Deputy County Counsel
Attorneys for Defendants County of Kern, Kern
County Probation Department, and David M. Kuge

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DATED: June 20, 2019

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GERAGOS & GERAGOS
/s/ Noah Geldberg (As authorized on 6/20/19)
Mark J. Geragos
Ben J. Meiselas
Noah Geldberg
Attorneys for Plaintiff Kim Adams

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ORDER

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IT IS SO ORDERED.
Dated:

June 24, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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Stipulation & [Proposed] Order to
Modify Scheduling Order

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