Lopez et al v. County of Kern et al

Filing 36

STIPULATION and ORDER 35 to Modify the Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 8/2/2018. Discovery Deadlines: Non-Expert 8/29/2018; Expert 12/28/2018. Non-Dispositive Motion Deadlines: Filed by 1/18/2019; Hearing by 2/15/2018. Dispositive Motion Deadlines: Filed by 3/8/2019; Hearing by 4/22/2019. Settlement Conference set for 1/7/2019 at 09:00 AM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. Pretrial Conference set for 6/13/2019 at 10:00 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. Jury Trial set for 8/13/2019 at 08:30 AM in Courtroom 2 (AWI) before District Judge Anthony W. Ishii. (Hall, S)

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RONALD O. KAYE, SBN 145051
KEVIN J. LaHUE, SBN 237556
KAYE, McLANE, BEDNARSKI & LITT, LLP
234 East Colorado Boulevard, Suite 230
Pasadena, California 91101
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs
ANA MARIA GONZALEZ LOPEZ
PEDRO DERKEVORKIAN
MARK L. NATIONS, COUNTY COUNSEL
COUNTY OF KERN, STATE OF CALIFORNIA
By: Marshall S. Fontes, Deputy (SBN 139567)
Kern County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, CA 93301
Telephone [phone]
Fax [phone]
Attorneys for Defendants
County of Kern, et al.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ANA MARIA GONZALEZ LOPEZ,
PEDRO DERKEVORKIAN, AND THE
ESTATE OF SERGIO DERKEVORKIAN,

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CASE NO.: 1:17-CV-00864-AWI-JLT
STIPULATION TO MODIFY THE
SCHEDULING ORDER; [PROPOSED]
ORDER; DECLARATION OF
MARSHALL S. FONTES RE
EXTRAORDINARY CAUSE

Plaintiff,
v.
COUNTY OF KERN; SHERIFF DONNY
YOUNGBLOOD; BILL WALKER,
DIRECTOR KERN COUNTY MENTAL
HEALTH DEPARTMENT; DEPUTY
ASHLEY MARCUM (#202548); and
DOES 1 through 10, inclusive,
Defendants.

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Stipulation to Modify the Scheduling Order; Proposed Order and Declaration of Marshall S. Fontes

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BY AND BETWEEN THE PARTIES TO THIS ACTION, THROUGH THEIR
COUNSEL OF RECORD:
This stipulation is entered into by and between the plaintiff and the defendants,

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by and through their respective counsel to modify the Scheduling Order in this matter,
by continuing all dates by approximately sixty (60) days.
1.

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As set forth in the attached declaration of Marshall S. Fontes, despite

the diligence of counsel, the parties have not been able to complete all necessary
discovery prior to the close of discovery in this case, due to a family medical
emergency suffered by defense counsel, which prevented scheduled discovery from
being completed.
2.

Based on the forgoing, the parties agree through counsel to amend the

scheduling order as follows:

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Deadline:

Currently:

Proposed:

Discovery cut off:

6/30/18

8/29/18

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Expert Disclosure:

9/1/18

10/31/18

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Supp. Expert Disclosure:

9/28/18

11/27/18

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Expert Discovery Cut Off:

10/27/18

12/28/18

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Non Dispositive Motion Filing:

11/19/18

1/18/19

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Non-Dispositive Motions:

12/17/18

2/15/19

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Dispositive Motion Filing:

1/7/19

3/8/19

Dispositive Motions:

3/18/19

5/17/19

Pre-Trial Conference:

4/30/19

6/29/19

Trial:

7/10/19

9/10/19

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3.

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Additionally, the Court has scheduled a Mandatory Settlement

Conference in this matter on October 26, 2018.

The parties request that the

settlement conference be continued to January 8, 2019 at 1:30 p.m. before Magistrate
Thurston.
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Stipulation to Modify the Scheduling Order; Proposed Order and Declaration of Marshall S. Fontes

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NOW THEREFORE, IT IS HEREBY STIPULATED by the Parties that the

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Scheduling Order be modified as set forth above.

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Dated: July 23, 2018

MARK L. NATIONS, COUNTY COUNSEL

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By:

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/s/ Marshall S. Fontes
Marshall S. Fontes, Deputy
Attorneys for Defendant, County of Kern

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Dated: July 23, 2018

KAYE, McLANE, BEDNARSKI & LITT, LLP

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By:

/s/ Kevin J. LaHue
Ronald O. Kay, Esq.
Kevin J. LaHue, Esq
Attorneys for Plaintiffs, Maria Lopez and
Pedro Derkevorkian

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Stipulation to Modify the Scheduling Order; Proposed Order and Declaration of Marshall S. Fontes

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PROPOSED ORDER

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THE COURT, HAVING FOUND GOOD CAUSE, AND PER STIPULATION OF
COUNSEL, IT IS HEREBY ORDERED that the Scheduling Order be Amended as
follows:
Deadline:

Currently:

Amended

Discovery cut off:

7/30/18

8/29/18

Expert Disclosure:

9/1/18

10/31/18

Supp. Expert Disclosure:

9/28/18

11/27/18

Expert Discovery Cut Off:

10/27/18

12/28/18

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Non Dispositive Motion Filing:

11/19/18

1/18/19

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Non-Dispositive Motions:

12/17/18

2/15/19

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Dispositive Motion Filing:

1/7/19

3/8/19

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Dispositive Motions:

3/18/19

4/2219, 1:30 p.m.

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Pre-Trial Conference:

4/30/19

6/13/19,10:00 a.m.

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Trial:

7/10/19

8/13/19, 8:30 a.m.

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The Mandatory Settlement Conference is continued to January 7, 2019 at 9:00

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a.m. before Magistrate Judge Thurston.

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IT IS SO ORDERED.
Dated:

August 2, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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Stipulation to Modify the Scheduling Order; Proposed Order and Declaration of Marshall S. Fontes