Mammen et al v. County of Sacramento et al

Filing 103

STIPULATION and ORDER signed by District Judge John A. Mendez on 5/8/2017 ORDERING that Pretrial Scheduling Order is MODIFIED as follows: Designation of Expert Witnesses due by 7/8/2017; Supplemental expert witness disclosure due by 7/29/2017; Completion of phase II discovery due by 9/1/2017; Dispositive Motions due by 10/19/2017; Phase II dispositive motions due by 10/10/2017; The hearing for phase II motions moved to 11/7/2017 at 1:30 PM. (Zignago, K.)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 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 Phone: 916-974-8500 Facsimile: 916-974-8510 Attorneys for Defendants County of Sacramento; Stephanie Lynch; Michelle Callejas; Debra Williams; Renae Rodocker; Luis Villa; and Craig Larkin LEIGH LAW GROUP Jay T. Jambeck SBN #226018 Mandy G. Leigh SBN # 225748 870 Market Street, Suite 1157 San Francisco, CA 94102 Telephone: 415-399-9155 Facsimile: 415-795-3733 Attorneys for Plaintiffs A.P. (a minor); Robin Mammen and Larry Mammen individually and as Guardian Ad Litem 16 UNITED STATES DISTRICT COURT 17 EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 18 19 20 21 22 23 24 25 26 A.P. (a minor); ROBIN MAMMEN and LARRY MAMMEN individually and as Guardian ad Litem for A.P., ) ) ) ) Plaintiffs, ) ) vs. ) ) COMMUNITY CARE LICENSING, ) COUNTY OF SACRAMENTO, STEPHANIE ) LYNCH, LUIS VILLA; MICHELLE ) CALLEJAS, DEBRA WILLIAMS, CRAIG ) LARKIN, RENAE RODOCKER, ) ) Defendants. ) ) Case No.: 2:13-cv-01588-JAM-AC STIPULATION AND ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER 27 28 STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER Page 1 1 COMES NOW THE PARTIES by and through their respective attorneys and subject to 2 the approval of this Court, hereby stipulate and respectfully request the following modifications 3 and/or amendments to this Court’s Pretrial Scheduling Order dated November 24, 2014 [ECF 4 No. 60]: 5 6  2017, be moved to July 8, 2017; 7 8     That the deadline for filing phase II dispositive motions, currently set for August 24, 2017, be moved to October 10, 2017; 15 16 That the deadline for filing dispositive motions, currently set for July 27, 2016, be moved to October 19, 2017; 13 14 That the completion of phase II discovery, currently set for July 24, 2017, be moved to September 1, 2017; 11 12 That the supplemental expert witness disclosure deadline, currently set for June 29, 2017, be moved to July 29, 2017; 9 10 That the expert witness disclosure deadline, currently set for June 8,  That the deadline for hearing phase II dispositive motions, currently 17 set for September 26, 2017, be moved to November 7, 2017 at 1:30 18 p.m.; 19 20 WHEREAS, counsel for all parties have met and discussed the posture of this case, and 21 agree that it would be in the interests of justice as set forth in the Declaration of John Lavra filed 22 herewith that good causes exists for a modification of the scheduling order; 23 WHEREAS, this stipulation and proposed order is based on the need for additional time 24 to conduct the above mentioned discovery, complete written discovery, and file pretrial motions; 25 WHEREAS, this request is not being made for the purpose of delay, or any other 26 27 28 improper purpose; and THEREFORE, IT IS HEREBY STIPULATED and agreed by and between the parties that this Court modifies the pretrial deadlines and trial date as set forth above. STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER Page 2 1 2 IT IS SO STIPULATED. 3 4 5 Dated: May 8, 2017 6 By: /s/ John A. Lavra JOHN A. LAVRA AMANDA L. MCDERMOTT 7 8 9 LONGYEAR, O’DEA & LAVRA, LLP Dated: May 8, 2017 10 LEIGH LAW GROUP /s/ Jay T. Jambeck By: JAY T. JAMBECK MANDY G. LEIGH 11 12 13 14 15 16 17 IT IS SO ORDERED AS MODIFIED BY THE COURT. Dated: _5/8/2017________________ /s/ John A. Mendez JOHN A. MENDEZ United States District Court Judge 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER Page 3

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