Gangstee et al v. County of Sacramento et al

Filing 19

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 4/14/2011 ORDERING 18 Non-Expert Discovery cut-off reset to 6/17/2011; Expert Witness Disclosure due by 7/15/2011; Supplemental Expert Witness Disclosure due by 8/5/2011; Expert Discovery by 9/16/2011. (Reader, L)

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LAW OFFICE OF STEWART KATZ
Stewart Katz, SBN 127425
Guy Danilowitz, SBN 257733
555 University Avenue, Suite 270
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

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LONGYEAR, O’DEA & LAVRA, LLP
John Lavra, SBN 114533
Jeri Pappone, SBN 210104
3620 American River Drive, Suite 230
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
County of Sacramento, John McGinness,
Stephen LeCouve

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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DEANNA GANGSTEE and JORDAN
CHAMBERS
Plaintiffs,
vs.

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STIPULATION AND
ORDER MODIFYING PRETRIAL
SCHEDULING ORDER

COUNTY OF SACRAMENTO, et al.,

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NO. 2:10-CV-01004-KJM-GGH

Defendants.
___________________________________/

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COME NOW THE PARTIES by and through their respective parties and subject to
the approval of this Court, hereby stipulate and respectfully request the following

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modifications and/or amendments to this Court’s July 7, 2010 Status (Pretrial Scheduling)

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Order (Docket #13), as modified by the Court’s January 5, 2011 Order (Docket #15),

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regarding the scheduling of this case:

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STIPULATION AND ORDER MODIFYING
PRETRIAL SCHEDULING ORDER

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That the non-expert discovery cut-off date currently set for April 17, 2011 be

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moved to June 17, 2011.

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That the expert witness disclosure cut-off date currently set for May 16, 2011 be

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moved to July 15, 2011.

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That the supplemental expert witness disclosure cut-off date currently set for

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June 7, 2011 be moved to August 5, 2011.

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That the expert discovery cut-off date currently set for July 15, 2011 be moved to

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September 16, 2011.

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This calendaring modification is requested because the availability of lead counsel

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for both parties has been affected by the recent death of the mother of counsel for one of

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the parties and a serious illness suffered by an immediate family member of counsel for the

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other party. In addition, Defendants inadvertently provided the wrong documents

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regarding applicable County policies that are at issue in this case. Defendants are planning

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on bringing a Motion for Summary Judgment prior to expert disclosure.

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Dated: April 12, 2011

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LAW OFFICE OF STEWART KATZ
/s/ Stewart Katz
STEWART KATZ,
Attorneys for Plaintiffs

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Dated: April 12, 2011

LONGYEAR, O’DEA & LAVRA, LLP
/s/ John Lavra
JOHN LAVRA
Attorneys for Defendants,
County of Sacramento, John McGinness,
Stephen LeCouve

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STIPULATION AND ORDER MODIFYING
PRETRIAL SCHEDULING ORDER

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IT IS SO ORDERED.
Dated: April 14, 2011.

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UNITED STATES DISTRICT JUDGE
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STIPULATION AND ORDER MODIFYING
PRETRIAL SCHEDULING ORDER

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