Gillaspy v. County of Sacramento

Filing 30

STIPULATION and ORDER 28 to modify 11 Scheduling Order signed by Judge Lawrence K. Karlton on 1/9/2012. The deadline for completing Discovery is continued to 3/30/2012. Disclosure of Expert Witnesses is now due by 1/30/2012. A Mid-Litigation Statement shall be submitted no later than 3/16/2012. The new deadline for Law and Motion to be completed for Judge Karlton by 5/30/2012. (Marciel, M) Modified on 1/9/2012 (Marciel, M).

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LAW OFFICES OF JOHNNY L. GRIFFIN, III
JOHNNY L. GRIFFIN, III (SBN 118694)
MANOLO H. OLASO (SBN 195629)
1010 F Street, Suite 200
Sacramento, California 95814
Telephone: [phone]
Fax: [phone]

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Attorneys for Plaintiff ALEXANDER GILLASPY
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RANDOLPH CREGGER & CHALFANT LLP
ROBERT L. CHALFANT (SBN 203051)
WENDY MOTOOKA (SBN 233589)
1030 G Street
Sacramento, CA 95814
Telephone: [phone]
Fax: [phone]

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Attorneys for Defendant COUNTY OF SACRAMENTO

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RIVERA & ASSOCIATES
JESSE M. RIVERA (SBN 84529)
2180 Harvard Street, Suite 310
Sacramento, CA 95815
Telephone: [phone]
Fax: [phone]

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Attorneys for Defendants Deputy Paul Labane
and Deputy Christopher Nelson

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IN THE UNITED STATES DISTRICT COURT

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IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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ALEXANDER GILLASPY,

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Law Offices of Johnny L. Griffin III
1010 F Street, Suite 200; Sacramento, CA 95814
[phone]
www.johnnygriffinlaw.com

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Plaintiff,
vs.
COUNTY OF SACRAMENTO; PAUL
LABANE; CHRISTOPHER NELSON,
Defendants.

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Case No. 2:10-CV-02753-LKK-EFB
STIPULATION TO MODIFY THE
SCHEDULING ORDER BY
CONTINUING THE DEADLINES FOR
COMPLETING DISCOVERY AND
COMPLETING LAW AND MOTION;
ORDER

Stipulation to Modify Scheduling Order; [Proposed] Order

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Plaintiff ALEXANDER GILLASPY and Defendants COUNTY OF SACRAMENTO,

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CHRISTOPHER NELSON, and PAUL LABANE, through their counsel of record, hereby stipulate

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to modify the Scheduling Order in this matter, if approved by the Court, as follows:

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1.

The deadline for completing discovery shall be continued from February 29, 2012 to

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March 30, 2012.
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2.

The deadline for disclosing experts shall be continued to January 30, 2012 (60 days

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before the close of discovery).
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3.

2012 (14 days prior to the close of discovery).

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The deadline for filing the mid-litigation statement shall be continued March 16,

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The deadline for completing law and motion shall be continued from April 30, 2012
to May 30, 2012.

This request is based on the sudden and unexpected death of a family member of Plaintiff’s

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attorney. Specifically, the family member passed away on December 28, 2011 and Plaintiff’s

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counsel will therefore be out of the office and unavailable for approximately 30 days. Good cause

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therefore exists for so modifying the Scheduling Order.

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Dated: December 29, 2011

Respectfully submitted,

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/s/ Johnny L. Griffin, III
JOHNNY L. GRIFFIN, III
Attorneys for Plaintiff ALEXANDER GILLASPY

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Law Offices of Johnny L. Griffin III
1010 F Street, Suite 200; Sacramento, CA 95814
[phone]
www.johnnygriffinlaw.com

Dated: December 29, 2011

/s/ Robert L. Chalfant
ROBERT L. CHALFANT
Attorneys for Defendant COUNTY OF SACRAMENTO

Dated: December 29, 2011

/s/ Jesse M. Rivera______
JESSE M. RIVERA
Attorneys for Defendant Paul Labane
Christopher Nelson

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Stipulation to Modify Scheduling Order; [Proposed] Order

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ORDER MODIFYING THE SCHEDULING ORDER
After considering the Stipulation by and between the parties through their counsel of record,
IT IS HEREBY ORDERED THAT:
1. The deadline for completing discovery shall be continued from February 29, 2012 to

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March 30, 2012.
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2. The deadline for disclosing experts shall be continued to January 30, 2012 (60 days
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before the close of discovery).
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3. The deadline for filing the mid-litigation statement shall be continued March 16, 2012
(14 days prior to the close of discovery).
4. The deadline for completing law and motion shall be continued from April 30, 2012 to

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May 30, 2012.

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IT IS SO ORDERED.

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Date: January 9, 2012.

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Law Offices of Johnny L. Griffin III
1010 F Street, Suite 200; Sacramento, CA 95814
[phone]
www.johnnygriffinlaw.com

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Stipulation to Modify Scheduling Order; [Proposed] Order

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