Gregoire v. County of Sacramento et al

Filing 38

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 10/2/14 re: 37 ORDERING that defendants shall have 21 days from the date this order is signed to complete the deposition of Plaintiff's expert (Mr. Bogardus), and 21 days to file a motion to compel, if necessary. There are no other changes to the scheduling order. (Meuleman, 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

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Attorneys for Defendants

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GARY W. GORSKI
Attorney at Law
1207 Front Street, Suite 15
Sacramento, CA 95814
Telephone: [phone]
email: [e-mail]
GARY W. GORSKI - CBN: 166526

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DANIEL M. KARALASH
Attorney at Law
1207 Front Street, Suite 15
Sacramento, CA 95814
Telephone: [phone]
email: [e-mail]
DANIEL M. KARALASH - SBN: 176422

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

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DAVID W. GREGOIRE
Plaintiff,
vs.

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COUNTY OF SACRAMENTO,
SHERIFF’S DEPARTMENT; COUNTY
OF SACRAMENTO; SHERIFF SCOTT
JONES, in his official capacity only;
DEPUTY ANTHONY JENKINS in his
individual capacity,
Defendant

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Case No.: 2:13-cv-01857-TLN-DAD
STIPULATION AN ORDER TO MODIFY
SCHEDULING ORDER RE: EXTEND
TIME FOR DEFENDANTS TO TAKE
PLAINTIFF’S EXPERT’S DEPOSITION.

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Stipulation and Order to Modify Scheduling Order
Page 1

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The Plaintiff David Gregoire, by and through his attorney Gary Gorski, and Defendants, by and
through their attorney, John Lavra stipulate as follows:
The purpose of this stipulation is to request that the court modify the existing scheduling order

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by extending the date which Defendant may depose Plaintiff’s expert. This is the second request and

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this will not interfere with the trial date currently set.

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The parties agree that Defendants’ served a timely Notice of Deposition, and that the deposition

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was scheduled well within discovery cut-off. The parties agreed to a modification of the deposition due

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to Mr. Gorski’s knee surgery, and had agreed upon 9/30/2014.

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Today, September 29, 2014, a problem arose with Mr. Gorski’s surgery, and he is scheduled for
admittance the morning of September 30, 2014.

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In light of the foregoing, the parties request the Court to modify the Scheduling Order as follows:

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Defendants shall have 21 days to complete the deposition of Plaintiff’s expert Mr. Bogardus, and

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21 days to file a motion to compel or overrule objections, if necessary. There are no other changes to

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the scheduling order.

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IT IS SO STIPULATED
Dated: September 29, 2014

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By: /s/ John A. Lavra
JOHN A. LAVRA
AMANDA L. MCDERMOTT
Attorneys for Defendants

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LONGYEAR, O’DEA & LAVRA, LLP

Dated: September 29, 2014

LAW OFFICES OF GARY GORSKI
By: /s/ Gary W. Gorski
GARY GORSKI
Attorney for Plaintiff

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Stipulation and Order to Modify Scheduling Order
Page 2

ORDER

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Defendants shall have 21 days from the date this order is signed to complete the deposition of

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Plaintiff’s expert (Mr. Bogardus), and 21 days to file a motion to compel, if necessary. There are no

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other changes to the scheduling order.

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IT IS SO ORDERED:

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Dated: October 2, 2014

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Troy L. Nunley
United States District Judge

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Stipulation and Order to Modify Scheduling Order
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