LM v. Kern High School District

Filing 21

STIPULATION and ORDER 20 to Extend Discovery Deadlines, signed by Magistrate Judge Jennifer L. Thurston on 7/2/2018. (Hall, S)

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DANIEL T. CLIFFORD, ESQ. – SBN 227632
DENNIS P. GALLAGHER, II, ESQ – SBN 301453
CLIFFORD & BROWN
A Professional Corporation
Attorneys at Law
Bank of America Building
1430 Truxtun Avenue, Suite 900
Bakersfield, CA 93301-5230
Tel: [phone] Fax: [phone]

[Filing fee exempt
Gov. Code § 6103]

Attorneys for Defendant,
KERN HIGH SCHOOL DISTRICT

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT

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***

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LM, a minor, by and through his Guardian ad
Litem, GRISELDA MARTIN,

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CASE NO. 1:17-CV-01123-DAD-JLT
STIPULATION TO EXTEND DISCOVERY
DEADLINES; [PROPOSED] ORDER
THEREON
(Doc. 20)

Plaintiff,
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vs.
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KERN HIGH SCHOOL DISTRICT, and
DOES 1 to 100, Inclusive,
Defendants.

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The parties in the above-captioned matter, Plaintiff, LM, by and through his Guardian as Litem,
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GRISELDA MARTIN (“Plaintiff”), by and through his attorneys of record, J. Miguel Flores of
Rodriguez & Associates, and Defendant KERN HIGH SCHOOL DISTRICT (“Defendant”) (Plaintiff
and Defendant are collectively referred to as the “Parties”), by and through its attorneys of record,

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Daniel T. Clifford and Dennis P. Gallagher, II, of Clifford & Brown, P.C., hereby enter into this
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Stipulation to Extend Discovery Deadlines, as follows:
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RECITALS
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WHEREAS the Parties have actively engaged in the discovery process to date, including the
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exchange of written discovery requests and responses, setting of approximately eight depositions to
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date, and a request by Defendant to inspect the home of Plaintiff;
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WHEREAS the Parties anticipate the need for a significant amount of additional non-expert
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1
Stipulation to Extend Discovery Deadlines

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and expert discovery;

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WHEREAS the Parties desire to extend the non-expert and expert discovery deadlines of July

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27, 2018 and September 21, 2018, respectively, for approximately two months to allow for such further

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discovery as the Parties deem appropriate.

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STIPULATION
IT IS HEREBY STIPULATED by and between the Parties that the non-expert discovery
deadline of July 27, 2018, be and hereby is continued to September 21, 2018.
IT IS FURTHER STIPULATED by and between the Parties that the expert discovery
deadline of September 21, 2018, be and hereby is continued to October 9, 2018.

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IT IS FURTHER STIPULATED that all other dates and deadlines set by the Court in its

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Scheduling Order dated November 20, 2017, remain on calendar or may be adjusted by the Court in its

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discretion.

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IT IS FURTHER STIPULATED that this stipulation may be signed in counterparts.

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DATED: June 26, 2018

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Dennis P. Gallagher, Esq. - /s/

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By ____________________________________
DANIEL T. CLIFFORD, ESQ.
DENNIS P. GALLAGHER, II, ESQ.
Attorneys for Defendant,
KERN HIGH SCHOOL DISTRICT

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CLIFFORD & BROWN

DATED: June ___, 2018

RODRIGUEZ & ASSOCIATES

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By ____________________________________
DANIEL RODRIGUEZ, ESQ.
J. MIGUEL FLORES, ESQ.
Attorneys for Plaintiff,
L.M., by and through his Guardian ad Litem,
Griselda Martin

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Stipulation to Extend Discovery Deadlines

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ORDER

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Based upon the foregoing, the Court ORDERS1:

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1.

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21, 2018;

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2.

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October 9, 2018.

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The non-expert discovery deadline of July 27, 2018, be and is continued to September

The expert discovery deadline of September 21, 2018, be and hereby is continued to

No other modifications to the case schedule are authorized and the Court anticipates
granting no further amendments to the case schedule.

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IT IS SO ORDERED.

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Dated:

July 2, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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In future, any stipulation to amend the case schedule SHALL describe the discovery that has not been completed
and an explanation why it has not been completed.
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Stipulation to Extend Discovery Deadlines