Reese, Jr. v. County of Sacramento et al

Filing 53

STIPULATION and ORDER signed by Judge John A. Mendez on 4/30/15 ORDERING that the Pretrial Scheduling Order, be modified and expert discovery be extended from 4/30/15 to 5/30/15, for the sole purpose of producing Defense Expert Peter Valentin for deposition. (Mena-Sanchez, L)

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

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LAW OFFICE OF STEWART KATZ
Stewart Katz, SBN # 127425
555 University Avenue, Suite 270
Sacramento, CA 95825
TEL: [phone]
LAW OFFICE OF DALE K. GALIPO
Dale K. Galipo, SBN #144074
21800 Burbank Blvd., Suite 310
Woodland Hills, CA 91367
TEL: [phone]
Attorneys for Plaintiff
ROBERT I. REESE, JR.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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

ROBERT I. REESE, JR.,

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Plaintiff,

STIPULATION AND ORDER TO EXTEND
EXERT DISCOVERY

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vs.
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.
Defendants.
/

Order entered on: 05/10/2013

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STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCOVERY
{01400000.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 Rules

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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 extend expert discovery to allow for additional time to conduct depositions of one of

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

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2.

Plaintiff agrees to extend the expert discovery deadline and allow Defendants up to and

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including May 30, 2015, to produce Defense Expert Peter Valentin. The close of discovery deadline is

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currently April 30, 2015. This extension shall not apply to any other expert or deadline, except as

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previously ordered for Dr. Bigelow.

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3.

Good cause exists to extend time due to the Court’s recent order dated March 23, 2015,

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to allow 10 additional depositions to go forward (Document 45) as well as the availability and

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scheduling conflicts of experts and counsel. The parties have scheduled 16 depositions in the month of

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April, including Rule 30(b)(6) depositions, and the depositions of non-retained and retained experts.

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Only two of which are now unable to move forward prior to the close of discovery due to conflicts. In

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addition, Counsel has had to travel to San Diego, Chicago, San Francisco, Hayward and now

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Connecticut in order to take and defend these depositions which has posed an addition challenge in

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scheduling them all in this limited amount of time. Accommodating Counsel’s schedule, travel, the

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additional depositions allowed, and the experts’ conflicts and availability have made it difficult, if not

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impossible to complete all expert depositions prior to April 30, 2015. The parties submit good cause

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exists to further modify the scheduling order to allow defense expert, Peter Valentin, to be deposed by

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May 30, 2015.

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4.

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

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

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20), January 5, 2015 (Document 31) and April 17, 2015 (Document 50.) The other deadlines including

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the dates originally set for trial, pretrial conference and dispositive hearing, as well as the associated

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deadlines, was previously modified by the Scheduling Order on June 17, 2014 (Document 20.)
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STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCOVERY
{01400000.DOC}

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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: April 30, 2015

LAW OFFICES OF STEWART KATZ

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By
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Dated: April 30, 2015

/s/ Stewart Katz (as authorized on 4/30/15)
Stewart Katz
Attorney for Plaintiff ROBERT REESE

LAW OFFICE OF DALE K. GALIPO

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By

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Dated: April 30, 2015

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/s/ Dale K. Galipo (as authorized on 4/30/15)
Dale K. Galipo
Attorney for Plaintiff ROBERT REESE

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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STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCOVERY
{01400000.DOC}

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ORDER

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Having reviewed the above stipulation and good cause appearing therefore, IT IS HEREBY

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ORDERED that the Pretrial Scheduling Order, be modified and expert discovery be extended from

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April 30, 2015 to May 30, 2015, for the sole purpose of producing Defense Expert Peter Valentin for
deposition.
IT IS SO ORDERED.

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Dated: 4/30/2015
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/s/ John A. Mendez____________
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER TO EXTEND EXPERT DISCOVERY
{01400000.DOC}