Staggs et al v. Doctors Hospital of Manteca, Inc. et al

Filing 287

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 3/30/2020 GRANTING the parties' request to extend the deadline to disclose rebuttal experts by 60 days. Defendants shall disclose their rebuttal expert(s) to Plaintiffs damages expert, Daniel Vasquez, by no later than 5/29/2020. The Joint Statement on whether leave to file any motion will be sought concerning the damages experts is now due by 6/9/2020.(Kastilahn, A)

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XAVIER BECERRA, SBN 118517
Attorney General of California
PETER A. MESHOT, SBN 117061
Supervising Deputy Attorney General
DIANA ESQUIVEL, SBN 202954
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendants Allen, Bangi, Krpan, and
St. Clair

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Michael R. Mordaunt, SBN 66911
Stephanie L. Roundy, SBN 211871
RIGGIO MORDAUNT & KELLY
A Professional Law Corporation
2509 West March Lane, Suite 200
Stockton, CA 95207
Telephone: [phone]
[e-mail]
Attorney for Defendant Mario Sattah, M.D.

Carter C. White, SBN 164149
U.C. Davis Civil Rights Clinic
One Shields Avenue, Bldg. TB-30
Davis, CA 95616-8821
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiffs Linnie Staggs,
as Administrator of the Estate of
Robert E. Staggs, and Melissa Staggs
Daniela P. Stoutenburg, SBN 183785
Carolyn L. Northrop, SBN 237989
DUMMIT, BUCKHOLZ & TRAPP
Attorneys At Law
1661 Garden Highway
Sacramento, CA 95833
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant Doctors
Hospital of Manteca, Inc.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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LINNIE STAGGS, as Administrator of the
ESTATE OF ROBERT E. STAGGS,
deceased, and MELISSA STAGGS,

STIPULATED REQUEST FOR 60-DAY
EXTENSION TO DISCLOSE
Plaintiffs, REBUTTAL EXPERT WITNESS AND
ORDER

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No. 2:11-cv-00414 MCE-KJN

v.
Trial Date:
None
Action Filed: June 9, 2011

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DOCTOR'S HOSPITAL OF MANTECA,
INC., et al.,
Defendants.

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Under Federal Rule of Civil Procedure 6(d)(a) and Local Rules 143 and 144, the parties, by
and through their attorneys of record, stipulate to and request a sixty-day extension of the March

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Stipulated Request for 60-Day Extension re Rebuttal Expert Witness (2:11-cv-0414 MCE-KJN)

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27, 2020 deadline for Defendants to disclose their rebuttal expert witness(es) primarily due to the

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effects of the coronavirus (COVID-19) outbreak.

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The Court previously extended the deadline for Defendants to disclose rebuttal expert

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witnesses by thirty-days. (ECF Nos. 284, 285.) Since the last extension, defense counsel, Diana

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Esquivel, had been pursuing some promising leads to locate the needed expert given that

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compassionate releases are a specialized niche with the California Department of Corrections and

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Rehabilitation (CDCR). However, given the events of the past three weeks involving the

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COVID-19 pandemic, proclamations of a state emergency from state and local officials for

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residents to shelter-in, and implemented telework schedules for many public agencies, including

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CDCR, Defendants have not been able to retain a rebuttal expert witness and will not be able to

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do so by the current deadline. The parties therefore agree to an additional sixty-day extension, up

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to and including May 29, 2020, for Defendants to disclose their rebuttal expert witness(es). The

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parties further agree to and request that the Court continue the April 9, 2020 deadline to file the

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Joint Statement concerning expert-related motions to June 9, 2020.

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IT IS SO STIPULATED.

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Dated: March 26, 2020

OFFICE OF THE ATTORNEY GENERAL

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/s/ Diana Esquivel
DIANA ESQUIVEL
Deputy Attorney General
Attorneys for Defendants Allen, Bangi, Krpan,
and St. Clair

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Respectfully submitted,

Dated: March 25, 2020

UC DAVIS CIVIL RIGHTS CLINIC
/s/ Carter White (authorized 3/25/2020)
CARTER C. WHITE
Attorneys for Plaintiffs Linnie and Melissa
Staggs

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Stipulated Request for 60-Day Extension re Rebuttal Expert Witness (2:11-cv-0414 MCE-KJN)

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Dated: March 25, 2020

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DUMMIT, BUCKHOLZ & TRAPP
/s/ Carolyn L. Northrop (authorized 3/25/20)
CAROLYN L. NORTHROP
Attorneys for Defendants Doctors Hospital of
Manteca, Inc.

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Dated: March 25, 2020

RIGGIO, MORDAUNT & KELLY

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/s/ Stephanie L. Roundy (authorized 3/25/20)
MICHAEL R. MORDAUNT
STEPHANIE L. ROUNDY
Attorneys for Defendant Mario Sattah, M.D.

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SA2011302076
14549526.docx

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Stipulated Request for 60-Day Extension re Rebuttal Expert Witness (2:11-cv-0414 MCE-KJN)

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ORDER

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Based on the parties’ stipulation and good cause appearing, the request to extend the
deadline to disclose rebuttal experts by sixty days is GRANTED.
Defendants shall disclose their rebuttal expert(s) to Plaintiffs’ damages expert, Daniel

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Vasquez, by no later than May 29, 2020.

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The Joint Statement on whether leave to file any motion will be sought concerning the

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damages experts is now due by June 9, 2020.

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Dated: March 30, 2020

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stag.414

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Stipulated Request for 60-Day Extension re Rebuttal Expert Witness (2:11-cv-0414 MCE-KJN)