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

Filing 291

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 6/12/2020 GRANTING the request to extend the deadline to disclose rebuttal experts by an additional four days. Defendants shall disclose their rebuttal expert(s) to Plaintiffs' damages expert, Daniel Vasquez, by no later than 6/16/2020. (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 FOURDAY 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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DOCTORS HOSPITAL OF MANTECA,
INC., et al.,
Defendants.

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

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Under Federal Rule of Civil Procedure 6(d)(a) and Local Rules 143 and 144, the parties, by

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and through their attorneys of record, stipulate to and request a four-day extension of the June 12,

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2020 deadline for Defendants to disclose their rebuttal expert witness(es). This extension is

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needed because Defendants’ newly identified rebuttal expert requires additional time to review

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the case material and complete her report.

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Defendants previously requested, and the Court granted, three extensions for Defendants to

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disclose rebuttal expert witnesses. (ECF Nos. 284-289.) Defendants’ last extension was needed

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due to the unexpected unavailability of the Classification Services Unit (CSU) employee who had

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intended to serve as a rebuttal witness in this case. With the assistance of CDCR, Defendants

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have identified an employee with the Board of Parole Hearings who is willing to serve as an

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expert. The Board employee has already started working on this matter; but given the amount of

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material that she must review, she requires a little more time to complete her report. Defendants

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therefore seek a short extension to June 16 to serve their disclosures.

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Plaintiffs agree to an additional four-day extension. No other deadline will be affected by
this request.
IT IS SO STIPULATED.

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Dated: June 11, 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: June 11, 2020

UC DAVIS CIVIL RIGHTS CLINIC
/s/ Carter White (authorized 6/11/2020)
CARTER C. WHITE
Attorneys for Plaintiffs Linnie and Melissa
Staggs

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

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Dated: June 11, 2020

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DUMMIT, BUCKHOLZ & TRAPP
/s/ Carolyn L. Northrop (authorized 6/11/20)
CAROLYN L. NORTHROP
Attorneys for Defendants Doctors Hospital of
Manteca, Inc.

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Dated: June 11, 2020

RIGGIO, MORDAUNT & KELLY

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/s/ Stephanie L. Roundy (authorized 6/11/20)
MICHAEL R. MORDAUNT
STEPHANIE L. ROUNDY
Attorneys for Defendant Mario Sattah, M.D.

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34149940.docx

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

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ORDER
Based on the parties’ stipulation and good cause appearing, the request to extend the
deadline to disclose rebuttal experts by an additional four days is GRANTED.
Defendants shall disclose their rebuttal expert(s) to Plaintiffs’ damages expert, Daniel
Vasquez, by no later than June 16, 2020.

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IT IS SO ORDERED.

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Dated: June 12, 2020

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