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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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
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION
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A.P. (a minor); ROBIN MAMMEN and
LARRY MAMMEN individually and as
Guardian ad Litem for A.P.,
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Plaintiffs,
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vs.
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COMMUNITY CARE LICENSING,
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COUNTY OF SACRAMENTO, STEPHANIE )
LYNCH, LUIS VILLA; MICHELLE
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CALLEJAS, DEBRA WILLIAMS, CRAIG )
LARKIN, RENAE RODOCKER,
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Defendants.
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Case No.: 2:13-cv-01588-JAM-AC
STIPULATION AND ORDER TO
MODIFY THE PRETRIAL SCHEDULING
ORDER
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STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER
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COMES NOW THE PARTIES by and through their respective attorneys and subject to
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the approval of this Court, hereby stipulate and respectfully request the following modifications
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and/or amendments to this Court’s Pretrial Scheduling Order dated November 24, 2014 [ECF
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No. 60]:
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2017, be moved to July 8, 2017;
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That the deadline for filing phase II dispositive motions, currently set
for August 24, 2017, be moved to October 10, 2017;
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That the deadline for filing dispositive motions, currently set for July
27, 2016, be moved to October 19, 2017;
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That the completion of phase II discovery, currently set for July 24,
2017, be moved to September 1, 2017;
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That the supplemental expert witness disclosure deadline, currently set
for June 29, 2017, be moved to July 29, 2017;
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That the expert witness disclosure deadline, currently set for June 8,
That the deadline for hearing phase II dispositive motions, currently
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set for September 26, 2017, be moved to November 7, 2017 at 1:30
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p.m.;
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WHEREAS, counsel for all parties have met and discussed the posture of this case, and
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agree that it would be in the interests of justice as set forth in the Declaration of John Lavra filed
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herewith that good causes exists for a modification of the scheduling order;
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WHEREAS, this stipulation and proposed order is based on the need for additional time
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to conduct the above mentioned discovery, complete written discovery, and file pretrial motions;
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WHEREAS, this request is not being made for the purpose of delay, or any other
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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
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IT IS SO STIPULATED.
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Dated: May 8, 2017
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By: /s/ John A. Lavra
JOHN A. LAVRA
AMANDA L. MCDERMOTT
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LONGYEAR, O’DEA & LAVRA, LLP
Dated: May 8, 2017
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LEIGH LAW GROUP
/s/ Jay T. Jambeck
By: JAY T. JAMBECK
MANDY G. LEIGH
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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
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STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER
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