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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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
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(Additional counsel on signature page)
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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HILLIARD WILLIAMS,
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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
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STIPULATION
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STIPULATION
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WHEREAS:
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(1)
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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;
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(4)
The Court has not yet set a trial date in this action;
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(5)
In the absence of a court-ordered expert discovery deadline, the parties agree that, for the
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avoidance of doubt, it is prudent to memorialize their understanding of the deadline for expert discovery
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in writing;
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NOW, THEREFORE, IT IS STIPULATED AND AGREED that, until and unless the Court
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issues an Order setting forth a separate expert discovery deadline, the deadline for disclosures of expert
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testimony shall be 90 days before the trial date ultimately set by the Court.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: August 2, 2017
JENNER & BLOCK LLP
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BY: /s/
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Pro Bono Attorneys for Plaintiff
HILLIARD WILLIAMS
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L. David Russell
L. David Russell
Dated: August 2, 2017
ATTORNEY GENERAL OF CALIFORNIA
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BY: /s/ Joseph R. Wheeler
(as authorized on July 31, 2017)
Joseph R. Wheeler
Attorneys for Defendant
DR. DAVID MATHIS, M.D.
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STIPULATION
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Dated: August 2, 2017
ANGELO, KILDAY & KILDUFF, LLP
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BY: /s/
Kevin J. Dehoff
(as authorized on August 1, 2017)
Kevin J. Dehoff
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Attorneys for Defendant
DR. JAROM A. DASZKO, M.D.
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IT IS SO ORDERED.
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Dated: August 10, 2017
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STIPULATION
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