Barron v. Martel et al

Filing 91

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 4/13/16 ORDERING that deadline to serve expert witness disclosures is EXTENDED to 5/13/2016. The deadline to serve rebuttal expert witness disclosures is EXTENDED to 6/13/2016. The deadline to complete all expert discovery, including depositions of expert witnesses, is EXTENDED to 7/29/2016. (Kastilahn, A)

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Alicia J. Donahue (SBN 117412)
[e-mail]
Amir Nassihi (SBN 235936)
[e-mail]
Andrew L. Chang (SBN 222309)
[e-mail]
SHOOK, HARDY & BACON L.L.P.
One Montgomery, Suite 2700
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Ronnie E. Barron

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
CHRISTOPHER J. BECKER, State Bar No. 230529
Supervising Deputy Attorney General
DIANA ESQUIVEL, State Bar No. 202954
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
Todd and Martinez

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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RONNIE E. BARRON,

Case No. 2:10-CV-01567-WBS-EFB (TEMP)

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Plaintiff,

STIPULATION AND ORDER TO EXTEND
EXPERT DISCOVERY DEADLINES

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v.
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M. MARTEL, et al.,
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Defendants.
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Complaint Filed: June 22, 2010

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Plaintiff Ronnie E. Barron (“Plaintiff”) and Defendants K. Martinez and K. Todd

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(“Defendants”), by and through their attorneys of record, hereby stipulate to extend the deadlines set

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by the Court in its Scheduling Order dated June 29, 2015. This stipulation shall not affect the pre-

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trial conference and trial dates.

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Good cause exists because Plaintiff’s counsel will be seeking to withdraw as counsel because

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of a fundamental disagreement on the scope, nature and direction of this case, including the next

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steps in prosecuting this action. Accordingly, counsel for Plaintiff will be seeking leave to withdraw

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as counsel of record. Thus, although Plaintiff and his counsel have been diligently working on

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efforts to prosecute this action, Plaintiff will require additional time to proceed on a pro se basis or

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secure counsel and engage in expert discovery so that Plaintiff may adequately prepare this case for

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trial, if necessary.

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Based on the foregoing, the parties stipulate to the following continuances:

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1. The deadline to serve expert witness disclosures shall be extended from April 14, 2016 to

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May 13, 2016.
2. The deadline to serve rebuttal expert witness disclosures shall be extended from June 1,
2016 to June 13, 2016.
3. The deadline to complete all expert discovery, including depositions of expert witnesses,
shall be extended from July 1, 2016 to July 29, 2016.

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Dated: April 11, 2016

Respectfully submitted,

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SHOOK, HARDY & BACON L.L.P.

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________/s/_____________
Alicia J. Donahue
Amir Nassihi
Andrew L. Chang

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Attorneys for Plaintiff
Ronnie E. Barron

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KAMALA D. HARRIS
Attorney General of California
DAVID A. CARRASCO
Supervising Deputy Attorney General

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________/s/_____________
DIANA ESQUIVEL
Deputy Attorney General
Attorneys for Defendants Todd and Martinez

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ORDER

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WHEREAS, good cause exists for the relief requested herein, the Court hereby makes the
foregoing Stipulation the Order of this Court.

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IT IS SO ORDERED.

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DATED: April 13, 2016.

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