Williams v. Daszko et al

Filing 78

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 08/10/17 ordering that, until and unless the Courtissues an Order setting forth a separate expert discovery deadline, the deadline for disclosures of experttestimony shall be 90 days before the trial date ultimately set by the Court. (Plummer, M)

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1 2 3 4 5 6 7 8 9 JENNER & BLOCK LLP L. David Russell (Cal. Bar No. 260043) drussell@jenner.com Wesley M. Griffith (Cal. Bar No. 286390) wgriffith@jenner.com Alexander M. Smith (Cal. Bar No. 295187) asmith@jenner.com Calvin R. Mohammadi (Cal. Bar No. 313675) cmohammadi@jenner.com 633 West 5th Street, Suite 3600 Los Angeles, California 90071 Telephone: (213) 239-5100 Facsimile: (213) 239-5199 Pro Bono Attorneys for Plaintiff Hilliard Williams 10 (Additional counsel on signature page) 11 12 UNITED STATES DISTRICT COURT 13 EASTERN DISTRICT OF CALIFORNIA 14 15 HILLIARD WILLIAMS, 16 17 18 19 20 Case No. 2:14-cv-1248 KJM AC JOINT STIPULATION AND PROPOSED ORDER REGARDING DEADLINE FOR EXPERT DISCOVERY Plaintiff, v. DR. JAROM A. DASZKO, M.D.; DR. DAVID MATHIS, M.D.; and DOES 1-25, inclusive, in their individual and official capacities, Defendants 21 22 23 24 25 26 27 28 STIPULATION 1 STIPULATION 2 WHEREAS: 3 (1) 4 5 6 7 8 The parties in this Section 1983 action anticipate the potential that one or more of the parties will offer expert testimony in this action; (2) On May 2, 2017, the Court issued an Order setting a discovery deadline in this action of August 4, 2017, which did not distinguish between fact and expert discovery; (3) Federal Rule of Civil Procedure 26(a)(2)(D)(i) provides that, absent a stipulation or court order, disclosures of expert testimony must be made at least 90 days before the date set for trial; 9 (4) The Court has not yet set a trial date in this action; 10 (5) In the absence of a court-ordered expert discovery deadline, the parties agree that, for the 11 avoidance of doubt, it is prudent to memorialize their understanding of the deadline for expert discovery 12 in writing; 13 NOW, THEREFORE, IT IS STIPULATED AND AGREED that, until and unless the Court 14 issues an Order setting forth a separate expert discovery deadline, the deadline for disclosures of expert 15 testimony shall be 90 days before the trial date ultimately set by the Court. 16 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 17 18 Dated: August 2, 2017 JENNER & BLOCK LLP 19 BY: /s/ 20 21 Pro Bono Attorneys for Plaintiff HILLIARD WILLIAMS 22 23 L. David Russell L. David Russell Dated: August 2, 2017 ATTORNEY GENERAL OF CALIFORNIA 24 25 26 27 BY: /s/ Joseph R. Wheeler (as authorized on July 31, 2017) Joseph R. Wheeler Attorneys for Defendant DR. DAVID MATHIS, M.D. 28 1 STIPULATION 1 Dated: August 2, 2017 ANGELO, KILDAY & KILDUFF, LLP 2 BY: /s/ Kevin J. Dehoff (as authorized on August 1, 2017) Kevin J. Dehoff 3 4 Attorneys for Defendant DR. JAROM A. DASZKO, M.D. 5 6 7 8 IT IS SO ORDERED. 9 10 Dated: August 10, 2017 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION

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