Reese, Jr. v. County of Sacramento et al

Filing 31

STIPULATION and ORDER to Modify 20 Scheduling Order signed by Judge John A. Mendez on 1/2/15 re: 30 ORDERING that the Pretrial Scheduling Order, be MODIFIED with the new schedule as set forth. Designation of Expert Witnesses due by 2/27/2015, Supplemental and Rebuttal witness disclosure deadline due 3/13/15. Discovery due by 4/30/2015. (Meuleman, A)

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

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Attorney for Plaintiff
ROBERT I. REESE, JR.

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A PROFESSIONAL CORPORATION
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John R. Whitefleet, SBN 213301
Taylor W. Rhoan, SBN 294941
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

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Attorneys for Defendants COUNTY OF SACRAMENTO, SCOTT JONES, JOSEPH MILLICAN,
ZACHARY ROSE, and DUNCAN BROWN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Plaintiff,

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Case No.: 2:13-cv-00559-JAM-DAD

ROBERT I. REESE, JR.,

STIPULATION AND ORDER TO MODIFY
SCHEDULING ORDER

vs.
Scheduling Order entered on: 05/10/2013

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COUNTY OF SACRAMENTO; Sacramento
County
Sheriff’s
Department
Deputy
DUNCAN
BROWN
(Badge
#1220);
Sacramento County Sheriff’s Department
Deputy ZACHARY ROSE (Badge #832);
Sacramento County Sheriff’s Department
Sergeant JOSEPH MILLICAN (Badge #246);
and Sacramento County Sheriff SCOTT
JONES.

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Defendants.
/

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STIPULATION AND [PROPOSED] ORDER TO MODIFY PRETRIAL SCHEDULING ORDER
{01337616.DOC}

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff ROBERT REESE

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and Defendants COUNTY OF SACRAMENTO, SCOTT JONES, JOSEPH MILLICAN, ZACHARY

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ROSE, and DUNCAN BROWN, by and through their undersigned Counsel, pursuant to Local Rule

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143 as follows:

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1.

The parties respectfully request that the District Court modify the Pretrial Scheduling

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Order to continue discovery deadlines to allow for additional time to conduct discovery of expert

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witnesses, based on good cause appearing as more fully set forth below.

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2.

The parties have previously modified discovery and expert disclosure deadlines on two

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prior occasions by Stipulation and Order on March 5, 2014 (Document 18) and June 17, 2014

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(Document 20.) The other deadlines including the dates originally set for trial, pretrial conference and

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dispositive hearing, as well as the associated deadlines, were previously modified by the Scheduling

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Order on June 17, 2014 (Document 20.)

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3.

Due to the large number of witnesses and potential experts has complicated the

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deadlines for disclosure and thus intruded on the time to conduct expert depositions, expert discovery

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and prepare expert reports. In addition, unexpected expert and scheduling complications have rendered

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the current discovery dates unworkable. The parties submit good cause exists to further modify the

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scheduling order to amend discovery deadlines only by two weeks each.

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4.

Therefore, the parties respectfully submit that good cause exists to amend the discovery

deadlines of the Pretrial Scheduling Order dated June 17, 2014, as follows:

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Deadline

Old Date

New Date

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Expert witness disclosure deadline

February 13, 2015

February 27, 2015

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Supplemental and Rebuttal witness

February 20, 2015

March 13, 2015

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disclosure deadline

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Close of discovery

April 17, 2015

April 30, 2015

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Dispositive motion filing

June 3, 2015

Unmodified

Dispositive motion hearing

July 1, 2015 at 9:30 a.m

Unmodified

Joint Pretrial Statement due

July 31, 2015

Unmodified

Pretrial Conference

August 7, 2015

Unmodified

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at 11:00 a.m.
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STIPULATION AND [PROPOSED] ORDER TO MODIFY PRETRIAL SCHEDULING ORDER
{01337616.DOC}

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Trial

September 14, 2015

Unmodified

at 9:00 a.m.

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This Stipulation may be signed in counterparts and any facsimile or electronic signature shall be
as valid as an original signature.
IT IS SO STIPULATED.

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Dated: January 2, 2015

LAW OFFICE OF STEWART KATZ

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By
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__/s/ Stewart Katz _as authorized on 12/30/14
Stewart Katz
Attorney for Plaintiff ROBERT REESE

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Dated: January 2, 2015

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By

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/s/ John R. Whitefleet
John R. Whitefleet
Taylor W. Rhoan
Attorneys
for
Defendants
COUNTY
OF
SACRAMENTO, DEPUTY DUNCAN BROWN,
DEPUTY ZACHARY ROSE, DEPUTY JOSEPH
MILLICAN, and SHERIFF SCOTT JONES

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ORDER
Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY
ORDERED that the Pretrial Scheduling Order, be modified with the new schedule as set forth above.
IT IS SO ORDERED.

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Dated: 1/2/2015

/s/ John A. Mendez____________
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER TO MODIFY PRETRIAL SCHEDULING ORDER
{01337616.DOC}