Moulton v. United States

Filing 18

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/19/2014 ORDERING that the non-expert discovery cutoff is EXTENDED to 4/18/2014; initial expert disclosures EXTENDED to 5/2/2014; supplemental expert disclosures EXTENDED to 5/16/2014. (Zignago, K.)

1 BENJAMIN B. WAGNER
United States Attorney
2 CHI SOO KIM
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
5
Attorneys for Defendant United States
6
7

IN THE UNITED STATES DISTRICT COURT

8

EASTERN DISTRICT OF CALIFORNIA

9
10

MARY MOULTON,

CASE NO. 2:12-CV-02596 TLN-CMK
Plaintiff,

11
v.

12
13

STIPULATION AND ORDER TO MODIFY
DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER

UNITED STATES OF AMERICA,
Defendant.

14
15
16

Plaintiff Mary Moulton and Defendant United States, by and through their respective counsel,

17 stipulate and respectfully request the below modification to discovery deadlines in the Court’s Pretrial
18 Scheduling Order (Dkt 14) for good cause. The parties do not request modification of any other dates.
19

1.

The parties respectfully request extending discovery deadlines due to the delay in

20 scheduling and conducting Plaintiff’s psychological independent medical examination, which was taken
21 on January 27-28, 2014. [Dkt 16] The parties have been working together to schedule deposition dates,
22 but have not been able to finalize those dates yet. In addition, Plaintiff’s counsel is scheduled to begin a
23 2-3 week long trial on March 3, 2014.
24

2.

The parties respectfully request extending deadlines for non-expert discovery from

25 February 21, 2014 to April 18, 2014; for initial expert disclosures from April 22, 2014 to May 2, 2014;
26 and for supplemental expert disclosures from May 12, 2014 to May 16, 2014. The Court previously
27 ordered that supplemental expert disclosures be made within twenty (20) days of initial expert
28 disclosures and the parties request shortening this time period to fourteen (14) days to avoid modifying
STIPULATION AND ORDER TO MODIFY DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER- Moulton v. United States, 2:12-cv-02596 TLN-CMK

30

1

1 the July 17, 2014 date set for the dispositive motion hearing.
2

3.

The parties do not request modification of any other dates, including the December 8,

3 2014 trial date.
Current

Proposed

Non-expert discovery cutoff:

February 21, 2014

April 18, 2014

Initial expert disclosures:

April 22, 2014

May 2, 2014

Supplemental expert disclosures:

May 12, 2014

May 16, 2014

Last day for motion hearing:

July 17, 2014

July 17, 2014 [same]

Joint Pretrial Statement:

September 11, 2014

September 11, 2014 [same]

11

Final Pretrial Conference:

October 9, 2014

October 9, 2014 [same]

12

Trial:

December 8, 2014

December 8, 2014 [same]

4
5
6
7
8
9
10

13
14
15

Dated: February 18, 2014

BENJAMIN B. WAGNER
United States Attorney
/s/ Chi Soo Kim
CHI SOO KIM
Assistant United States Attorney

16
17
18
Dated: February 18, 2014

LAW OFFICE OF ROBERT L. DAVIS

19
/s/ Robert L. Davis
ROBERT L. DAVIS
Attorney for Plaintiff

20
21
22

ORDER

23
24 IT IS SO ORDERED.
25
26 Dated: February 19, 2014
27
28

Troy L. Nunley
United States District Judge
STIPULATION AND ORDER TO MODIFY DISCOVERY DEADLINES IN PRETRIAL
SCHEDULING ORDER- Moulton v. United States, 2:12-cv-02596 TLN-CMK

30

2