Inthavongxay v. County of Sacramento et al

Filing 30

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 6/22/2015 ORDERING 29 Disclosure of Expert Witnesses EXTENDED to 8/26/2015; and the time for the rebuttal reports EXTENDED to 9/22/2015. (Reader, L)

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A PROFESSIONAL CORPORATION
David P.E. Burkett, SBN 241896
Ariana A. Van Alstine, SBN 296624
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

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Attorneys for Defendant
COUNTY OF SACRAMENTO

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Exempt From Filing Fees Pursuant to Government Code § 6103

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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CHARLET INTHAVONGXAY,
Plaintiff,

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v.

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No. 2:13-cv-02249-WBS-DAD
JOINT STIPULATION AND ORDER TO
EXTEND EXPERT DISCLOSURE AND
REBUTTAL DEADLINE

COUNTY OF SACRAMENTO ET AL.,

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Defendants
___________________________________/

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This Stipulation is entered into by and between Plaintiff CHARLET INTHAVONGXAY

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and Defendant COUNTY OF SACRAMENTO. The Parties have conferred and agree to continue

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the expert disclosure date for 61 days, from June 26, 2015 to August 26, 2015, and the rebuttal

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reports 60 days, from July 24, 2015 to September 22, 2015.

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The parties have good cause to request an extension for the expert disclosure deadline

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because the discovery process was delayed by the late completion of Rule 26(a)(1) Disclosures.

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Defendant provided Rule 26(a)(1) disclosures on December 8, 2014. However, Plaintiff’s Rule

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26(a)(1) Disclosures were not provided until March 23, 2015. After receiving Plaintiff’s Rule

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26(a)(1) Disclosures, Defendant propounded discovery and anticipates responses within the next

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week. In addition, the parties are planning the deposition of Katherine Nickerson at Plaintiff’s
{01422225.DOCX}

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request, and the deposition of Plaintiff, Charlet Inthavongxay at Defendant’s request.

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The Parties wish to postpone the expert disclosures until they have had a chance to receive

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discovery responses and take depositions. The Parties stipulate to extend the expert disclosure

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date to August 26, 2015. Accordingly, the time for the rebuttal reports will need to be extended as

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well. The parties agree to September 22, 2015 as the date for the rebuttal reports. This will still

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allow for Discovery to be completed by the present November 6, 2015 deadline and need not
disrupt the remaining trial schedule. The amended schedule also comports with the Federal
Requirement that disclosures be made 90 days before trial. Fed. R. Civ. P. 26(a)(2)(D).
Respectfully submitted,

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PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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Dated: June 19, 2015

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RUSSELL A. ROBINSON

By /s/ Russell A. Robinson (authorized on 6/19/15)
Russell A. Robinson
Attorney for Plaintiff
CHARLET INTHAVONGXAY

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Dated: June 22, 2015

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PORTER SCOTT

A PROFESSIONAL CORPORATION

By /s/ Ariana A. Van Alstine______________
David P.E. Burkett
Ariana A. Van Alstine
Attorneys for Defendant
COUNTY OF SACRAMENTO

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{01422225.DOCX}

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ORDER

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Pursuant to the parties’ stipulation, IT IS SO ORDERED.
Dated: June 22, 2015

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Ddad1\orders.civil
inthavongxay2249.stip.eot.ord.docx

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PORTER | SCOTT

350 University Avenue, Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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