Mammen et al v. County of Sacramento et al

Filing 63

STIPULATION AND ORDER signed by District Judge John A. Mendez on 1/20/2016 MODIFYING the 60 Status (Pretrial Scheduling) Order; ORDERING that expert witnesses be disclosed by 7/15/2016 and that supplemental expert witnesses be disclosed by 7/29/201 6; ORDERING that all discovery be completed by 9/16/2016; ORDERING that dispositive motions be filed by 10/18/2016 and that said motions be heard on 11/15/2016 at 01:30 PM; ORDERING that the Joint Pretrial Statement be filed by 1/6/2017; CONTINUING the Final Pretrial Conference 1/13/2017 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez; CONTINUING the Jury Trial 2/13/2017 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Michel, G.)

1
2
3
4
5
6
7
8
9
10
11
12

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

13
14
15

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
AMENDED STIPULATION AND ORDER
TO MODIFY THE PRETRIAL
SCHEDULING ORDER

27
28
AMENDED STIPULATION AND [PROPOSED] ORDER TO
MODIFY THE PRETRIAL SCHEDULING ORDER
Page 1

COMES NOW THE PARTIES by and through their respective attorneys and subject to

1
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



July 15, 2016;

6
7







That the deadline for filing dispositive motions, currently set for July 27, 2016, be moved
to October 18, 2016;

12
13

That the deadline for all discovery (expert and non-expert) to be completed, currently set
for June 15, 2016, be moved to September 16, 2016;

10
11

That the supplemental expert witness disclosure deadline, currently set for April 29,
2016, be moved to July 29, 2016;

8
9

That the expert witness disclosure deadline, currently set for April 15, 2016, be moved to



That the deadline for hearing on dispositive motions, currently set for August 24, 2016,
be moved to November 15, 2016, at 1:30 p.m.;

14
15



That the deadline for filing the Joint Pretrial Statement be set for January 6, 2017;

16



That the Final Pretrial Conference, currently set for September 30, 2016, be moved to
January 13, 2017, at 11:00 a.m.; and

17
18



That the Trial, currently set for November 7, 2016, be moved to February 13, 2017, at

19

9:00 a.m.

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 and judicial economy and that good causes exists

22

for a modification of the scheduling order;

23

WHEREAS, the parties, through written discovery and meet and confer efforts, have

24

determined that the relevant documents in this matter are in excess of 2,000 pages, and that due

25

to the number of parties and witnesses there will be a significant number of necessary

26

depositions;

27
28

WHEREAS, due to the nature of the claims in this matter the parties are likely to require
the services of one or more experts, who will need to review significant records in order to
AMENDED STIPULATION AND [PROPOSED] ORDER TO
MODIFY THE PRETRIAL SCHEDULING ORDER
Page 2

1
2
3
4

prepare their reports as required by FRCP 26;
WHEREAS, the parties would like to complete written discovery and depositions related
to non-expert witnesses prior to disclosure of experts;
WHEREAS, this stipulation and proposed order is based on the need for additional time

5

to conduct the above mentioned discovery, complete written discovery, and file pretrial motions;

6

WHEREAS, this request is not being made for the purpose of delay, or any other

7
8
9
10

improper purpose;
WHEREAS, continuing the trial date and pretrial deadlines will not prejudice any party
or their counsel; and
THEREFORE, IT IS HEREBY STIPULATED and agreed by and between the parties

11

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

12

IT IS SO STIPULATED.

13
14

Dated: January 20, 2016

LONGYEAR, O’DEA & LAVRA, LLP

15
By: /s/ Amanda L. McDermott
JOHN A. LAVRA
AMANDA L. MCDERMOTT

16
17
18

Dated: January 20, 2016

LEIGH LAW GROUP

19
/s/ Jay T. Jambeck
By: JAY T. JAMBECK
MANDY G. LEIGH

20
21
22
23
24

IT IS SO ORDERED.

25
26
27

Dated: _1/20/2016_________________

/s/ John A. Mendez
JOHN A. MENDEZ
United States District Court Judge

28
AMENDED STIPULATION AND [PROPOSED] ORDER TO
MODIFY THE PRETRIAL SCHEDULING ORDER
Page 3