Mammen et al v. County of Sacramento et al

Filing 68

AMENDED STIPULATION and ORDER TO MODIFY PRETRIAL SCHEDULING ORDER signed by District Judge John A. Mendez on 07/11/16 ORDERING the following dates are RESET as follows: Designation of Expert Witnesses due by 10/17/16 with any supplemental/rebuttal expert disclosures due by 10/31/16; Discovery completed by 11/21/16; all Dispositive Motions filed by 12/21/16 and heard 01/24/17 at 1:30 p.m.; Final Pretrial Conference set for 06/09/17 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A . Mendez with a joint pretrial statement due 06/02/17; Jury Trial set for 07/17/17 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez; Settlement Conference set for 9/9/2016 at 09:30 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney (cc: CKD). (Benson, A)

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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, P.C.
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
AMENDED STIPULATION AND ORDER
TO MODIFY THE PRETRIAL
SCHEDULING ORDER TO
PARTICIPATE IN AN EARLY
SETTLEMENT CONFERENCE

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AMENDED STIPULATION AND ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER TO
PARTICIPATE IN AN EARLY SETTLEMENT CONFERENCE
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COMES NOW THE PARTIES by and through their respective counsel and subject to the

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approval of this Court, hereby stipulate and respectfully request that this Court’s Pretrial

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Scheduling Order dated January 20, 2016 [ECF No. 63], be modified to reflect new deadlines as

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follows, or as to accommodate the Court’s docket, in order for the parties to participate in an

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early settlement conference:

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Current Date

New Date

Expert Disclosure:

July 15, 2016

Oct. 17, 2016

Supplemental Expert Disclosure:

July 29, 2016

Oct. 31, 2016

Close of All Discovery:

Sept. 16, 2016

Nov. 21, 2016

Filing of Dispositive Motions:

Oct. 18, 2016

Dec. 21, 2016

Hearing of Dispositive Motions:

Nov. 15, 2016

Jan. 24, 2017, at 1:30p

Joint Pretrial Statement:

Jan. 6, 2017

June 2, 2017

Final Pretrial Conference:

Jan. 13, 2017

June 9, 2017 at 11:00a

Trial:

Feb. 13, 2017

July 17, 2017

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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 and judicial economy and that good causes exists

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for the modification of the scheduling order;

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WHEREAS, the parties have agreed to participate in a judicially supervised settlement

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conference with Magistrate Judge Carolyn Delaney on September 9, 2016 at 9:30 a.m., and

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allowing the parties to extend the deadlines as requested will save the parties time and expenses

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while they pursue potential settlement;

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WHEREAS, this request is not being made for the purpose of delay, or any other
improper purpose;
WHEREAS, continuing the trial date and pretrial deadlines will not prejudice any party
or their counsel; and

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AMENDED STIPULATION AND ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER TO
PARTICIPATE IN AN EARLY SETTLEMENT CONFERENCE
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THEREFORE, IT IS HEREBY STIPULATED and agreed by and between the parties

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

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IT IS SO STIPULATED.

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Dated: July 11, 2016

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: July 11, 2016

LEIGH LAW GROUP, P.C.

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

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IT IS SO ORDERED.

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Dated: July 11, 2016
__________________

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

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AMENDED STIPULATION AND ORDER TO MODIFY THE PRETRIAL SCHEDULING ORDER TO
PARTICIPATE IN AN EARLY SETTLEMENT CONFERENCE
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