Manning et al v. Crosby et al

Filing 33

STIPULATION AND ORDER signed by District Judge Troy L. Nunley on 4/1/2016 ORDERING that discovery be completed by 5/13/2016; ORDERING all parties to disclose expert witnesses by 6/28/2016; ORDERING that dispositive motions be heard by 11/3/2016; CONF IRMING that Joint Final Pretrial Conference Statements be filed by 2/2/2017; CONFIRMING the Final Pretrial Conference set for 2/9/2017 at 02:00 PM in Courtroom 2 (TLN) before District Judge Troy L. Nunley; CONFIRMING the Jury Trial set for 4/3/2017 at 09:00 AM in Courtroom 2 (TLN) before District Judge Troy L. Nunley. (Michel, G.)

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LONGYEAR, O’DEA & LAVRA, LLP
John A. Lavra, CSB No.: 114533
Amanda L. McDermott, CSB No.: 253651
3620 American River Drive, Suite 230
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]

LAW OFFICE OF JOSEPH C. GEORGE
Joseph C. George, Sr., SBN 119231
Joseph George, Jr., SBN 200999
601 University Avenue, Suite 200
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendants,
COUNTY OF SACRAMENTO
and LYNN TRACY

Attorneys for Plaintiffs

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LAW OFFICE OF STEWART KATZ
Stewart Katz, SBN 127425
555 University Avenue, Suite 270
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LILLY MANNING, KENYATA MANNING,
and NATASHA MANNING,
Plaintiffs,
vs.
MIKE CROSBY, RACHEL LANE, MARY
STRUHS, NATASHA JOHNSON,
STEPHANIE WHITNEY-COOK, PAULINE
TRACEY, LYNN TRACY, MSW,
SACRAMENTO UNIFIED SCHOOL
DISTRICT, DEPARTMENT OF HEALTH
AND HUMAN SERVICES, CHILD
PROTECTIVE SERVICES, SACRAMENTO
COUNTY, and DOES 5 through 25, inclusive,
Defendants.

NO. 2:12-CV-01784-TLN-KJN
STIPULATION AND ORDER TO
MODIFY PRETRIAL SCHEDULING
ORDER

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STIPULATION AND REQUEST TO MODIFY SCHEDULING ORDER
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Plaintiffs Lilly Manning, Kenyata Manning and Natasha Manning, (collectively

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referred to hereinafter as “Plaintiffs”) are represented by Joseph C. George and Joseph C.

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George, Jr., of the Law Offices of Joseph C. George, 601 University Avenue, Suite 200,

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Sacramento, California 95825, and Stewart Katz of the Law Office of Stewart Katz, 555

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University Avenue, #270, Sacramento, California 95825.

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Defendants County of Sacramento and Lynn Tracy, MSW (collectively referred to

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hereinafter as “Sacramento County Defendants”) are represented by John A. Lavra and

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Amanda McDermott of Longyear, O’Dea & Lavra, LLP.

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Defendants Mike Crosby, Rachel Lane, Mary Struhs, Natasha Johnson, Stephanie

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Whitney-Cook, Pauline Tracey and Sacramento Unified School District were dismissed

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from this action on August 18, 2015. (ECF 27.)

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Pursuant to Federal Rule of Civil Procedure 16(b)(4), the parties hereby stipulate and

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request that the Scheduling Order issued on December 2, 2015 (ECF 31) be modified to

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reflect new deadlines as follows, or as to accommodate the Court’s docket:

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Discovery Deadline:

May 13, 2016

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Expert Witness Disclosure:

June 28, 2016

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Dispositive Motion Deadline:

October 13, 2016*

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Joint Final Pretrial Conference Statement:

January 26, 2017*

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Final Pretrial Conference:

February 2, 2017, at 2:00 p.m.*

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Trial:

April 3, 2017, at 9:00 a.m.*

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*no change to prior scheduling order

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The parties stipulate to and request this extension of the discovery and expert witness

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disclosure deadlines in order to accommodate the serious health condition of Defendant

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Lynn Tracy, which affects her ability to attend and sit for a deposition. The parties have met

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and conferred regarding these health concerns. In order to accommodate these concerns, the

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parties require additional time to complete Ms. Tracy’s deposition.

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STIPULATION AND REQUEST TO MODIFY SCHEDULING ORDER
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This is a very complicated and factually intensive case. It has involved extensive

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discovery and experienced various unexpected delays. The discovery and expert disclosure

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deadlines as currently set would make competent defense or prosecution of this case

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impossible. The parties are confident that the new deadlines for discovery and expert

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disclosure would provide all parties with adequate time to complete dispositive motions and

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have the case prepared for trial by the currently scheduled trial date.

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IT IS SO STIPULATED.

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Dated: March 31, 2016

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THE LAW OFFICE OF JOSEPH C. GEORGE, PH.D
By: /s/ Joseph C. George
JOSEPH C. GEORGE
JOSEPH C. GEORGE, JR
Attorneys for Plaintiffs

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Dated: March 31, 2016

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LAW OFFICE OF STEWART KATZ
By: /s/ Stewart Katz
STEWART KATZ
Attorneys for Plaintiffs

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Dated: March 31, 2016

LONGYEAR, O’DEA & LAVRA, LLP
By: /s/ Amanda McDermott
JOHN LAVRA
AMANDA MCDERMOTT
Attorneys for Defendants County of Sacramento and
Lynn Tracy, MSW

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STIPULATION AND REQUEST TO MODIFY SCHEDULING ORDER
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ORDER
Good cause appearing, the Court hereby modifies the Pretrial Scheduling Order as
follows:

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Discovery Deadline:

May 13, 2016

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Expert Witness Disclosure:

June 28, 2016

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Dispositive Motion Hearing Deadline:

November 3, 2016

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Joint Final Pretrial Conference Statement:

February 2, 2017

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Final Pretrial Conference:

February 9, 2017, at 2:00 p.m.

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Trial:

April 3, 2017, at 9:00 a.m.

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IT IS SO ORDERED.

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Dated: April 1, 2016

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Troy L. Nunley
United States District Judge

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STIPULATION AND REQUEST TO MODIFY SCHEDULING ORDER
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