Isgar v. City of Bakersfield et al

Filing 47

STIPULATION and ORDER 46 Modifying the Scheduling Order, signed by Magistrate Judge Jennifer L. Thurston on 11/22/2019. Non-Dispositive Motions filed by 4/24/2020. Dispositive Motions filed by 6/1/2020. Pretrial Conference CONTINUED to 7/20/2020 at 10:00 AM in Bakersfield, 510 19th Street before Magistrate Judge Jennifer L. Thurston. (Hall, S)

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Michael G. Marderosian, No. 77296
Heather S. Cohen, No. 263093
MARDEROSIAN & COHEN
1260 Fulton Street
Fresno, CA 93721
Telephone: [phone]
Facsimile: [phone]
Virginia Gennaro, No. 138877
City Attorney
CITY OF BAKERSFIELD
1501 Truxtun Avenue
Bakersfield, CA 93301
Telephone: [phone]
Facsimile: [phone]

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Attorneys for:

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Defendants CITY OF BAKERSFIELD, RYAN MAXWELL, TRAVIS
McNINCH, ROBERTO FIGUEROA JR., BRANDON DOYLE, EDGAR
GALDAMEZ, and JEREMIAH HOLT

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GLORIA JEAN ISGAR,
Plaintiff,

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vs.

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CITY OF BAKERSFIELD, et al.
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Defendants.

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Case No. 1:18-CV-00433-JLT
STIPULATION TO MODIFY SCHEDULING
ORDER [DKT. NO. 37]; [PROPOSED]
ORDER THEREON

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RECITALS

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1.

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WHEREAS, on December 13, 2018, this Court issued its Scheduling Order [Dkt. No. 37]

setting the deadline to complete discovery as December 6, 2019;
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WHEREAS, Plaintiff’s counsel intends to depose six additional defense witnesses, four of

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which he estimates will take six or more hours and two of which he estimates will take over three or four
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hours;

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following:
a.

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WHEREAS, additional time is necessary to take these depositions these due to the

Defense counsel has depositions scheduled every week day between now and

December 2, 2019 save and except for November 28, 2019 and November 29, 2019, the Thanksgiving
Holiday.
b.

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On December 2, 2019 and December 9, 2019, Defense counsel is scheduled to start

the trial in the case of Bowman v. Bowman, Kern County Superior Court Case No. S-1501-FL-623414.
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c.
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Defense counsel has depositions scheduled for December 4, 2019, December 5,

2019, and December 6, 2019.

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d.

Following the current December 6, 2019 discovery cut off, Defense counsel has

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various depositions and hearings scheduled throughout the state of California that would make scheduling

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the depositions in this case very difficult.
e.

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Defense counsel will be extremely busy with depositions in the case of Fajardo v.

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City of Bakersfield, United States District Court Case No. 1:16-CV-00699-JLT, which are not complete, as

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well as a trial starting January 14, 2020 before the Honorable Judge Anthony Ishii (Willis v.Mullins, et al.,

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Case No. 1:04-cv-6542) and then the Fajardo case in this Court on February 10, 2020.
4.

WHEREAS, in the light of the above, the Parties have agreed to an extension and propose

the below dates:
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Deadline/Hearing
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Current Date

Proposed Date

Non-Expert Discovery Cutoff

12/06/2019

03/06/2020

Expert Disclosure

12/20/2019

03/13/2020

Rebuttal Expert Disclosure

01/17/2020

03/30/2020

Expert Discovery Cutoff

02/14/2020

04/17/2020

Non-Dispositive Motions

02/28/2020

04/24/2020

Hear Non-Dispositive Motions

03/27/2020

05/26/2020

Dispositive Motions

04/17/2020

06/1/2020

Hear Dispositive Motions

05/27/2020

06/29/2020

PreTrial Conference

07/08/2020

07/20/2020

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4.

WHEREAS, the requested extension will not affect the trial date of September 14, 2020, or

any of the dates related thereto.

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STIPULATION
IT IS HEREBY STIPULATED by and between the Parties hereto through their respect attorneys
of record that the following dates be extended as follows:
Deadline/Hearing

Current Date

Proposed Date

Non-Expert Discovery Cutoff

12/06/2019

03/06/2020

Expert Disclosure

12/20/2019

03/13/2020

Rebuttal Expert Disclosure

01/17/2020

03/30/2020

Expert Discovery Cutoff

02/14/2020

04/17/2020

Non-Dispositive Motions

02/28/2020

04/24/2020

Hear Non-Dispositive Motions

03/27/2020

05/26/2020

Dispositive Motions

04/17/2020

06/1/2020

Hear Dispositive Motions

05/27/2020

06/29/2020

PreTrial Conference

07/08/2020

07/20/2020

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Dated: November 22, 2019

LAW OFFICE OF ALFRED R. HERNANDEZ

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/s/ Alfred R. Hernandez
By:________________________________
Alfred R. Hernandez,
Attorneys for Plaintiff

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Dated: November 22, 2019.

MARDEROSIAN & COHEN
/s/ Michael G. Marderosian
By:________________________________
Michael G. Marderosian,
Attorneys for Defendants
above-named.

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ORDER
Pursuant to the Stipulation of the Parties and good cause appearing therefor, IT IS HEREBY
ORDERED that the Scheduling Order [Dkt No. 37] be modified to extend the dates as follows:
Deadline/Hearing

Current Date

New Date

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Non-Expert Discovery Cutoff

12/06/2019

03/06/2020

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Expert Disclosure

12/20/2019

03/13/2020

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Rebuttal Expert Disclosure

01/17/2020

03/30/2020

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Expert Discovery Cutoff

02/14/2020

04/17/2020

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Non-Dispositive Motions

02/28/2020

04/24/2020

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Hear Non-Dispositive Motions

03/27/2020

05/26/2020

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Dispositive Motions

04/17/2020

06/1/2020

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Hear Dispositive Motions

05/27/2020

06/29/2020

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PreTrial Conference

07/08/2020

07/20/2020

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IT IS SO ORDERED.
Dated:

November 22, 2019

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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