Mayfield v. Orozco, et al.

Filing 115

STIPULATION and ORDER signed by District Judge John A. Mendez on 6/29/16 ORDERING that Expert disclosures are now due on 9/22/2016. Supplemental expert and rebuttal expert disclosures are now due on 10/7/2016. The present discovery cutoff date of 1 0/14/2016 shall remain in place, except for purposes of depositions of experts only, which shall be continued to the date of 10/26/2016. All other discovery deadlines, and all law and motion and trial dates established previously by the court's pretrial Scheduling Order dated 4/20/2015 shall remain in effect.(Kastilahn, A)

1 WILKE, FLEURY, HOFFELT, GOULD
& BIRNEY, LLP
2 ROBERT F. TYLER, JR. (SBN 63055)
[e-mail]
3 NEAL C. LUTTERMAN (SBN174681)
[e-mail]
4 400 Capitol Mall, Twenty-Second Floor
Sacramento, California 95814
5 Telephone:
[phone]
Facsimile:
[phone]
6 Attorneys for Defendants Regents of the
University Of California, now sued as The
7 University Of California Davis Health
System, and Dr. Gregory Sokolov and Dr.
8 Robert Hales

PORTER SCOTT
John R. Whitefleet, Esq.
[e-mail]
Adam Debow, Esq.
[e-mail]
350 University Avenue, Suite 200
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant Ivan Orozco

9 HADSELL STORMER & RENICK LLP LONGYEAR, O'DEA & LAVRA, LLP
Barbara Enloe Hadsell, Esq.
Van Longyear, Esq.
10 [e-mail]
[e-mail]
Joshua Piovia-Scott, Esq.
Peter C. Zilaff, Esq.
11 [e-mail]
[e-mail]
Daniel Stormer, Esq.
Nicole Cahill, Esq.
12 [e-mail]
[e-mail]
Acrivi Coromelas, Esq.
13 [e-mail]
3620 American River Drive, Ste. 230
Caitlan McLoon, Esq.
Sacramento, CA 95864
14 [e-mail]
Telephone: [phone]
128 N. Fair Oaks Ave.
Facsimile: [phone]
15 Pasadena, CA 91103
Attorneys for Defendants County Of Sacramento;
Telephone: [phone]
Scott Jones, Sheriff; James Lewis; Rick Pattison
16 Facsimile: 626-577-7079
RIFKIN LAW OFFICE
17 Lori Rifkin, Esq.
[e-mail]
18 P.O. Box 19169
19 Oakland, CA 94619
Facsimile: [phone]
20 Attorneys for Plaintiffs James Joshua
Mayfield, James Allison Mayfield, Jr., and
21 Terri Mayfield
UNITED STATES DISTRICT COURT
22
EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
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24 JAMES JOSHUA MAYFIELD; et al.,
Plaintiffs,

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26

ATTORNEYS AT LAW
SACRAMENTO

STIPULATION RE: EXTENSION OF
EXPERT DISCOVERY DEADLINES

v.

27 IVAN OROZCO; et al.,
Defendants.
28
W I LK E , F LE U R Y ,
H O F FE L T , G O U LD &
B IR NE Y , LLP

Case No. 2:13-CV-02499-JAM-AC

1465625.1 STIPULATION RE: EXTENSION OF DATES

OF EXPERT DISCOVERY DEADLINES

Complaint Filed: December 3, 2013
1st Amended Complaint Filed: March 26, 2014
2nd Amended Complaint Filed: March 19, 2015
3rd Amended Complaint Filed: June 22, 2015
Trial Date: May 1, 2017
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2:13-CV-02499-JAM-AC

1 IT IS HEREBY STIPULATED BY THE PARTIES TO ACTION NO. 2:13-CV-02499-JAM-AC
2 AS FOLLOWS:
3

WHEREAS, on December 3, 2013, plaintiffs James Joshua Mayfield, James Allison Mayfield,

4 Jr. and Terry Mayfield (hereafter, collectively referred to as “plaintiffs”) filed the instant action
5 against defendants Ivan Orozco, Sheriff Scott Jones, James Lewis, Rick Pattison, County of
6 Sacramento, University of California Davis Health System, Dr. Gregory Sokolov, in his individual
7 capacity, and Dr. Robert Hales (hereafter, collectively referred to as “defendants”); and
8

WHEREAS, on April 20, 2015, the court filed its Status (Pretrial Scheduling) Order, in which

9 the court set forth all the operative dates governing scheduling of events in this case. In its order, the
10 court ordered expert disclosures under Federal Rule of Civil Procedure 26(a)(2) to take place by
11 August 12, 2016. Supplemental disclosures and disclosure of rebuttal experts under Federal Rule of
12 Civil Procedure 26(a)(2)(c) were to be made by August 26, 2016. The court further ordered that all
13 discovery, including all depositions, be completed by October 14, 2016; and
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WHEREAS, the parties to this action have been working diligently to complete discovery, it

15 has come to light that it will be difficult, if not impossible, to complete an independent medical
16 examination (“IME”) of plaintiff James Joshua Mayfield, and complete the disclosure of expert
17 reports, and complete the depositions of experts, by the dates set forth above; and
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WHEREAS, the parties have met and conferred and have agreed, and hereby stipulate, to an

19 extension of the expert discovery deadlines as follows:
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1.

Extend the expert disclosure date from August 12, 2016 to September 22, 2016;

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2.

Extend the supplemental expert and rebuttal expert disclosure date from August 26,

22 2016 to October 7, 2016;
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3.

The present discovery cutoff date of October 14, 2016 shall remain in place, except for

24 purposes of depositions of experts only, which shall be continued to the date of October 26, 2016;
4.

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All other discovery deadlines, and all law and motion and trial dates established

26 previously by the court's pretrial Scheduling Order dated April 20, 2015 shall remain in effect.
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W I LK E , F LE U R Y ,
H O F FE L T , G O U LD &
B IR NE Y , LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION RE: EXTENSION OF DATES OF
EXPERT DISCOVERY DEADLINES

-2-

2:13-CV-02499-JAM-AC
1465625.1

1

It is hereby stipulated, by and between the parties through their respective counsel of record,

2 that the expert discovery deadlines may be extended as set forth above, subject to approval of the
3 court.
4 DATED: June 29, 2016

WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP

5

By:

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DATED: June 29, 2016

// NEAL C. LUTTERMAN
NEAL C. LUTTERMAN
ROBERT F. TYLER, JR.
Attorneys for Defendants
REGENTS OF THE UNIVERSITY OF CALIFORNIA,
now sued as the UNIVERSITY OF CALIFORNIA DAVIS
HEALTH SYSTEM, and DR. GREGORY SOKOLOV,
and DR. ROBERT HALES
HADSELL STORMER & RENICK LLP
By:

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DATED: June 29, 2016

RIFKIN LAW OFFICE
By:

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// BARBARA ENLOE HADSELL
BARBARA ENLOE HADSELL
DAN STORMER
JOSH PIOVIA-SCOTT
ACRIVI COROMELAS
CAITLAN McLOON
Attorneys for Plaintiffs
JAMES JOSHUA MAYFIELD, JAMES ALLISON
MAYFIELD, JR., and TERRI MAYFIELD

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19

// LORI RIFKIN
LORI RIFKIN
Attorneys for Plaintiffs
JAMES JOSHUA MAYFIELD, JAMES ALLISON
MAYFIELD, JR., and TERRI MAYFIELD

20 DATED: June 29, 2016

LONGYEAR, O'DEA & LAVRA, LLP

21

By:

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// VAN LONGYEAR
VAN LONGYEAR
PETER ZILAFF
NICOLE CAHILL
Attorneys for Defendants
COUNTY OF SACRAMENTO; SCOTT JONES,
SHERIFF; JAMES LEWIS; RICK PATTISON

25 DATED: June 29, 2016

PORTER SCOTT

26

By:

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W I LK E , F LE U R Y ,
H O F FE L T , G O U LD &
B IR NE Y , LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION RE: EXTENSION OF DATES OF
EXPERT DISCOVERY DEADLINES

// JOHN R. WHITEFLEET
JOHN R. WHITEFLEET
ADAM DEBOW
Attorneys for Defendant
IVAN OROZCO
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2:13-CV-02499-JAM-AC
1465625.1

1
ATTESTATION REGARDING SIGNATURES
2
I, Neal C. Lutterman, hereby attest that all other signatories listed, and on whose behalf the
3
filing is submitted, concur in the filings content and have authorize the filing.
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DATED: June 29, 2016

// NEAL C. LUTTERMAN
Neal C. Lutterman

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W I LK E , F LE U R Y ,
H O F FE L T , G O U LD &
B IR NE Y , LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION RE: EXTENSION OF DATES OF
EXPERT DISCOVERY DEADLINES

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2:13-CV-02499-JAM-AC
1465625.1

1
2

ORDER OF RE: EXTENSION OF EXPERT DISCOVERY DEADLINES
Based upon the foregoing Stipulation of the parties and good cause appearing, it is hereby

3 ordered that:
4

1.

Expert disclosures are now due on September 22, 2016;

5

2.

Supplemental expert and rebuttal expert disclosures are now due on October 7, 2016;

6

3.

The present discovery cutoff date of October 14, 2016 shall remain in place, except for

7 purposes of depositions of experts only, which shall be continued to the date of October 26, 2016;
8

4.

All other discovery deadlines, and all law and motion and trial dates established

9 previously by the court's pretrial Scheduling Order dated April 20, 2015 shall remain in effect.
10
11 Dated: 6/29/2016

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

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W I LK E , F LE U R Y ,
H O F FE L T , G O U LD &
B IR NE Y , LLP
ATTORNEYS AT LAW
SACRAMENTO

STIPULATION RE: EXTENSION OF DATES OF
EXPERT DISCOVERY DEADLINES

-5-

2:13-CV-02499-JAM-AC
1465625.1