Mammen et al v. County of Sacramento et al

Filing 74

ORDER signed by District Judge John A. Mendez on 9/21/2016 ORDERING Close of Phase 1 Discovery: Discovery due by 11/21/2016; Dispositive Motions Phase 1, filed by 12/21/2016, Hearing of Dispositive Motions, Phase 1, 1/24/2017 at 1:30 PM; Expert Discl osure due by 6/8/2017; Supplemental Expert Disclosure by 6/29/2017; Close of Phase 2 Discovery: Discovery due by 7/24/2017; Dispositive Motion, Phase 2, due 8/22/2017, Hearing of Dispositive Motions, Phase 2, 9/19/2017 at 1:30 PM; Joint Pretrial Stat ement due by 12/1/2017; Final Pretrial Conference set for 12/8/2017 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez; and Trial set for 1/8/2018 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Reader, L)

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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
STIPULATION AND ORDER TO
MODIFY THE PRETRIAL SCHEDULING
ORDER TO ALLOW FOR PHASED
DISCOVERY

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AMENDED STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING
ORDER TO ALLOW FOR PHASED DISCOVERY
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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 July 12, 2016 [ECF No. 68], 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 conduct phased

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discovery moving forward:
Current Schedule

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Expert Disclosure:

Oct. 17, 2016

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Supplemental Expert Disclosure:

Oct. 31, 2016

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Close of All Discovery:

Nov. 21, 2016

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Filing of Dispositive Motions:

Dec. 21, 2016

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Hearing of Dispositive Motions:

Jan. 24, 2017, at 1:30p

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Joint Pretrial Statement:

June 2, 2017

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Final Pretrial Conference:

June 9, 2017 at 11:00a

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Trial:

July 17, 2017

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Proposed New Schedule

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Close of Phase 1 Discovery:

Nov. 21, 2016

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Filing of Dispositive Motions, Phase 1:

Dec. 21, 2016

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Hearing of Dispositive Motions, Phase 1:

Jan. 24, 2017, at 1:30p

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Expert Disclosure:

June 8, 2017

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Supplemental Expert Disclosure:

June 29. 2017

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Close of Phase 2 Discovery:

July 24, 2017

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Filing of Dispositive Motion, Phase 2:

August 22, 2017

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Hearing of Dispositive Motions, Phase 2:

September 19, 2017, at 1:30p

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Joint Pretrial Statement:

December 1, 2017

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Final Pretrial Conference:

December 8, 2017, at 11:00a

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Trial:

January 8, 2018 at 9:00 a.m.

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AMENDED STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING
ORDER TO ALLOW FOR PHASED DISCOVERY
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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 participated in a judicially supervised settlement conference with

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Magistrate Judge Carolyn Delaney on September 9, 2016, but were unable to reach a settlement;

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WHEREAS, during the settlement conference on September 9, the parties discussed with

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Judge Delaney, and she approved, the possibility of conducting phased discovery moving

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forward in order for the parties to conduct limited fact discovery prior to Defendants filing their

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motion for summary judgment, and postponing expert discovery and any other fact discovery

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depending on the outcome of Defendants’ motion;
WHEREAS, allowing the parties to extend the deadlines as requested will save the

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parties time and expenses in an effort to resolve the purely legal questions incumbent in this

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case;

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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
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: September 20, 2016

LONGYEAR, O’DEA & LAVRA, LLP

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

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AMENDED STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING
ORDER TO ALLOW FOR PHASED DISCOVERY
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Dated: September 20, 2016

LEIGH LAW GROUP, P.C.

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

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IT IS SO ORDERED.

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Dated: 9/21/2016____________

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

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AMENDED STIPULATION AND [PROPOSED] ORDER TO MODIFY THE PRETRIAL SCHEDULING
ORDER TO ALLOW FOR PHASED DISCOVERY
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