Tandel v. County of Sacramento, et al

Filing 127

STIPULATION and ORDER for Extension of Time for Initial and Supplemental Disclosure of Expert Witnesses and Deadline for Expert Witness Depositions signed by Chief Judge Morrison C. England, Jr on 4/22/14 re: 124 . (Meuleman, A)

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LONGYEAR, O’DEA & LAVRA, LLP
VAN LONGYEAR, CSB NO. 84189
PETER C. ZILAFF, CSB NO. 272658
3620 American River Drive, Suite 230
Sacramento, California 95864-5923
Tel: [phone] Fax: [phone]

Attorneys for Defendants County of Sacramento,
John McGinness, Ann Marie Boylan, Michael Sotak, M.D.,
Susan Kroner RN, Agnes R. Felicano NP, Glayol Sahba, M.D.,
Deputy John Wilson, Richard Bauer, M.D., Deputy Stephanie Jacoby,
Deputy Mark Medeiros, Deputy Mark Iwasa, Shelley Jordan

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SANDIPKUMAR TANDEL,
Plaintiff,

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vs.
COUNTY OF SACRAMENTO, et al.,
Defendants.

CASE NO. 2:11-cv-00353 MCE AC
[Consolidated with 2:09-cv-00842 MCE GGH]

STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR INITIAL
& SUPPLEMENTAL DISCLOSURE OF
EXPERT WITNESSES AND DEADLINE
FOR EXPERT WITNESS
DEPOSITIONS

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Plaintiff, Sandipkumar Tandel, is represented by Geri Green and Julien Swanson of the

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Law Offices of Geri Lynn Green, LC and Dennise S. Henderson of the Law Office of Dennise S.

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Henderson. Defendants, Attorneys for Defendants County of Sacramento, John McGinness, Ann

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Marie Boylan, Michael Sotak, M.D., Susan Kroner RN, Agnes R. Felicano NP, Glayol Sahba,

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M.D., Deputy John Wilson, Richard Bauer, M.D., Deputy Stephanie Jacoby, Deputy Mark

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Medeiros, Deputy Mark Iwasa, and Shelley Jordan (“County of Sacramento, et al.”) are

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represented by Van Longyear and Peter C. Zilaff of Longyear, O’Dea & Lavra, LLP. Defendant

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Chris Smith, M.D. is represented by Norman V. Prior of Porter Scott.

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Good cause exists to modify the pretrial scheduling order to extend the time for the initial
disclosure of experts, supplemental experts and discovery and depositions of expert witnesses.
The extensive discovery conducted to date has motivated the parties to explore settlement

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through mediation. Rule 26 expert reports are currently scheduled to be exchanged on or before

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April 1, 2014. The parties believe that resources might be better devoted to mediation rather

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than devoted to the preparation of final reports and therefore wish to extend the date to exchange

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to and including May 15, 2014.

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The brief extension of time to complete the expert witness disclosures and depositions

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will allow the parties an opportunity to potentially dispose of the case before expending
unnecessary expert witness expenses. Thus, the parties respectfully request an extension for the

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initial expert disclosure date, the supplemental expert disclosure date and the last date for parties

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to complete expert discovery and depositions, as follows:

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Initial disclosure of experts
Supplemental disclosure of experts

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Dated: March 18, 2014

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LAW OFFICE OF GERI GREEN
/S/: Geri Green_______________
GERI GREEN
Attorneys for Plaintiff

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May 1, 2014 until June 30, 2014.

IT IS SO STIPULATED:

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April 21, 2014 until May 28, 2014

Expert witness discovery/depositions

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April 1, 2014 until May 15, 2014

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Stipulation and [Proposed] Order
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Dated: March 18, 2014

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PORTER SCOTT
/S/: Norman V. Prior_______________
NORMAN V. PRIOR
Attorneys for Defendant,
Chris Smith, M.D.

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Dated: March 18, 2014

/S/: Van Longyear _________________
VAN LONGYEAR
Attorneys for Defendants,
County of Sacramento, et al.

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LONGYEAR, O’DEA & LAVRA, LLP

ORDER
IT IS SO ORDERED.

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Dated: April 22, 2014

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Stipulation and [Proposed] Order
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