Mammen et al v. County of Sacramento et al

Filing 109

STIPULATION and ORDER signed by District Judge John A. Mendez on 9/6/2017 ORDERING the Close of Phase 2 Discovery is EXTENDED to 11/9/2017. (Washington, S)

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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: [phone]
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: [phone]
Facsimile: 415-795-3733

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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 June 30, 2017 [ECF No.

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105]:

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

That the close of phase 2 discovery, currently set for September 22, 2017, be moved
to November 9, 2017;

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WHEREAS, counsel for all parties have met and discussed the posture of this case, and
agree that it would be in the interests of justice and judicial economy and that good causes exists
for the modification of the scheduling order;
WHEREAS, the parties continue to engage in settlement discussions and need additional
time to determine whether resolution of this matter without further litigation is possible;

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WHEREAS, the parties require additional time to complete expert discovery;

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WHEREAS, the parties do not intend to file further dispositive 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

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that this Court modifies the pretrial deadlines as set forth above.

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IT IS SO STIPULATED.

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Dated: September 6, 2017

LONGYEAR, O’DEA & LAVRA, LLP

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By: /s/ Amanda L. McDermott
JOHN A. LAVRA
AMANDA L. MCDERMOTT

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Dated: September 6, 2017

LEIGH LAW GROUP

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/s/ Jay T. Jambeck
By: JAY T. JAMBECK
MANDY G. LEIGH

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STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER
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IT IS SO ORDERED.

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Dated: _9/6/2017_________________

/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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