Oreizi v. County of Fresno

Filing 27

Stipulation and Order to continue dates set in the Court's scheduling order Document 19 , dated 04/15/19; Document 21 , dated 07/29/19;Document 23 dated 10/15/19 and Document 25 dated 12/4/9, signed by Magistrate Judge Erica P. Grosjean on 1/30/2020. (Non expert Discovery due by 2/14/2020; Expert Disclosure due by 2/14/2020; Rebuttal Expert Disclosures 3/20/2020; Expert Discovery due by 3/30/2020) (Rosales, O.)

[Exempt From Filing Fee
Government Code § 6103]
1 McCormick, Barstow, Sheppard,
Wayte & Carruth LLP
2 Mart B. Oller IV, #149186
7647 North Fresno Street
3 Fresno, California 93720
Telephone:
[phone]
4 Facsimile:
[phone]
5 Attorneys for Defendant COUNTY OF FRESNO
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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11 FARSHAD OREIZI,

Case No. 1:18-CV-00662-AWI-EPG

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STIPULATION AND ORDER TO
CONTINUE DATES SET IN THE
COURT’S SCHEDULING ORDER
DOCUMENT 19, DATED 04/15/19;
DOCUMENT 21, DATED 07/29/19;
DOCUMENT 23 DATED 10/15/19 and
DOCUMENT 25 DATED 12/4/9

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Plaintiff,
v.

14 COUNTY OF FRESNO and DOES 1 through
20, inclusive,
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Defendants.
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(ECF No. 26)

IT IS HEREBY STIPULATED BY AND AMONG, Defendant County of Fresno and

18 Plaintiff Farshad Oreizi, through their respective counsel:
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Defendant County of Fresno and Plaintiff Farshad Oreizi, referred to herein as the “Parties,”

20 hereby stipulate, request, and consent to the Court entering an Order to continue the dates set by this
21 Court in Document 15 as set forth herein below. The parties mediated the case on August 13, 2019,
22 without success and thereafter agreed to brief continuances regarding non-expert discovery to
23 accommodate plaintiff’s counsel’s vacation and defendant’s counsel’s and his family’s health
24 issues, and a trial in Federal court. (Document 19, 22, 25.)
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This request and stipulation is based on the fact that due to unavoidable delays encountered

26 in proceeding with the completion of non-expert discovery, due to counsel for Defendant, Mart
27 Oller, having a recent bout with the flu, the parties have had to reschedule some of the depositions
28 and will need two additional weeks beyond the current cut-off date in which to complete same. The
MCCORMICK, BARSTOW ,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

STIPULATION AND ORDER TO CONTINUE DATES SET IN THE COURT’S SCHEDULING ORDER
DOCUMENT 19, DATED 04/15/19; DOCUMENT 21, DATED 07/29/19;
DOCUMENT 23 DATED 10/15/19 and DOCUMENT 25 DATED 12/4/19

1 parties believe that the interests of judicial economy and justice are best served by the requested
2 continuance of the dates below, which preserves the current trial date, pretrial date, and dispositive
3 motion filing date.
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DISCOVERY DEADLINES:

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Non-Expert Discovery:

Current date: January 31, 2020

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Proposed New Date:

February 14, 2020

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Expert Disclosure:

Current date: January 31, 2020

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Proposed New Date:

February 14, 2020

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Rebuttal Expert Disclosure:

Current date: February 20, 2020

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Proposed New Date:

March 20, 2020

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Expert Discovery:

Current date: February 5, 2020

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Proposed New Date:

March 30, 2020

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All other terms, conditions, and deadlines in the Court’s Scheduling Conference

14 Order (ECF No. 15, and 25) shall remain in full force and effect.
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IT IS SO STIPULATED.

16 Dated: January 30, 2020

McCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP

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/s/ Mart B. Oller
Mart B. Oller IV
Attorneys for Defendant COUNTY OF FRESNO
By:

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MCCORMICK, BARSTOW ,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

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STIPULATION AND ORDER TO CONTINUE DATES SET IN THE COURT’S SCHEDULING ORDER

1 Dated: Janaury __, 2020

LAW OFFICE OF PETER SEAN BRADLEY

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/s/ Peter Sean Bradley
Peter Sean Bradley
Attorneys for Plaintiff FARSHAD OREIZI

By:
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MCCORMICK, BARSTOW ,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

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STIPULATION AND ORDER TO CONTINUE DATES SET IN THE COURT’S SCHEDULING ORDER

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ORDER
Based in part on the parties’ stipulation (ECF No. 26), and with good cause shown, the Court

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3 hereby ORDERS that the Scheduling Order (Doc. 15) as previously modified (ECF Nos. 19, 21, 23,
4 25), is further modified as follows:
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EVENT

PRIOR DATE

CONTINUED DATE

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Non-Expert Discovery Cutoff

January 31, 2020

February 14, 2020

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Expert Disclosures

January 31, 2020

February 14, 2020

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Rebuttal Expert Disclosures

February 20, 2020

March 20, 2020

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Expert Discovery Completion

March 5, 2020

March 30, 2020

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Pretrial Conference

June 19, 2020, at 10:00 a.m.

June 19, 2020, at 10:00 a.m.

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Trial

August 18, 2020, at 8:30 a.m.

August 18, 2020, at 8:30 a.m.

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13 IT IS SO ORDERED.
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Dated:
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January 30, 2020

/s/
UNITED STATES MAGISTRATE JUDGE

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MCCORMICK, BARSTOW ,
SHEPPARD, W AYTE &
CARRUTH LLP
7647 NORTH FRESNO STREET
FRESNO, CA 93720

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STIPULATION AND ORDER TO CONTINUE DATES SET IN THE COURT’S SCHEDULING ORDER