Hammond v. County of Tehama et al

Filing 30

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 7/28/2016 ORDERING the deadline for Expert Disclosure shall be CONTINUED from 8/11/2016 to 10/11/2016; the deadline for Rebuttal Expert Disclosure shall be CONTINUED from 8/31/2016 t o 10/31/2016; the deadline for completing Expert Discovery shall be CONTINUED from 9/30/2016 to 11/30/2016; the deadline for filing Dispositive Motions shall be CONTINUED from 11/7/2016 to 12/12/2016; the Dispositive Motions Hearing Date shall be CONTINUED from 12/8/2016 to 1/12/2017. (Jackson, T)

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A PROFESSIONAL CORPORATION
Stephen E. Horan, SBN 125241
Hovannes G. Nalbandyan, SBN 300364
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

Attorneys for Defendant, 30th DISTRICT AGRICULTURAL ASSOCIATION

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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RICHARD HAMMOND ,

CASE NO.: 2:15-CV-0068-TLN-CMK

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Plaintiff,

PORTER | SCOTT

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

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v.

JOINT STIPULATION FOR
CONTINUANCE OF PRE-TRIAL DATES
AND ORDER

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COUNTY OF TEHAMA; 30TH DISTRICT
AGRICULTURAL ASSOCIATION, a state
institution of the State of California and DOES
1-10, inclusive.

Complaint Filed: 1/12/2015

Defendants.
___________________________________/

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WHEREAS, Defendant 30TH DISTRICT AGRICULTURAL ASSOCIATION (“30TH DAA),

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and Plaintiff RICHARD HAMMOND (“HAMMOND”) by and through their respective counsel of

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record hereby agree as follows:

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1. WHEREAS, on or about January 12, 2015, HAMMOND filed his original Complaint;

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2. WHEREAS, on or about April 10, 2015, the parties agreed to participate in the Voluntary

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Dispute Resolution Program (“VDRP”). The parties could not reach an agreement;

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3. WHEREAS, on October 22, 2015, the parties filed a Joint Scheduling Report;

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4. WHEREAS, on December 7, 2015, the Court entered its Pre-Trial Scheduling Order;

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JOINT STIPULATION FOR CONTINUANCE OF PRE-TRIAL DATES AND ORDER

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5. WHEREAS, the parties have been engaged in discovery in the above-captioned action,

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including written discovery, production of documents, and depositions;

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6. WHEREAS, HAMMOND obtained a stipulation from 30th DAA to file a First-Amended

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Complaint to add an additional defendant, RED BLUFF ROUND-UP ASSOCIATION,

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which was previously omitted from the complaint;

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7. WHEREAS, on July 22, 2016, the Court granted Plaintiff’s Motion for Leave to Amend

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Complaint to join additional Defendant, RED BLUFF ROUND-UP ASSOCIATION;

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8. WHEREAS, Plaintiff will file his First Amended Complaint no later than July 29, 2016;

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9. WHEREAS, Parties anticipate the Court will vacate the due dates and hearing dates set in

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the current Pretrial Scheduling Order once Plaintiff files the First Amended Complaint;

PORTER | SCOTT

10. WHEREAS, this case is set for trial on May 8, 2017;

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

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11. WHEREAS, Parties continue to engage in discovery;

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12. WHEREAS, Parties submit there is good cause to continue the pretrial deadlines identified

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herein by approximately 60 days to allow parties to complete remaining discovery in this

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matter;

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13. WHEREAS, Parties are only seeking a continuance of those dates identified below and are

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not seeking a continuance of the trial date in this matter; and

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14. WHEREAS, the Parties have previously requested an extension to conduct a deposition

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after the discovery cutoff date, but have not requested a continuance of any of the other

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pretrial dates set by the Court in this matter.

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STIPULATION:
NOW THEREFORE, it is agreed and stipulated by and between the parties, through their

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respective counsel of record, that the follow dates previously set by order of the Court be continued

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as follows:

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

The deadline for Expert Disclosure shall be continued from August 11, 2016 to October 11,
2016.

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JOINT STIPULATION FOR CONTINUANCE OF PRE-TRIAL DATES AND ORDER

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

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October 31, 2016.


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The deadline for completing Expert Discovery shall be continued from September 30, 2016
to November 30, 2016.



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The deadline for Rebuttal Expert Disclosure shall be continued from August 31, 2016 to

The deadline for filing Dispositive Motions shall be continued from November 7, 2016 to
December 12, 2016.

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The Dispositive Motions Hearing Date shall be continued from December 8, 2016 to
January 12, 2017.

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shall remain as previous scheduled by the Court, unless the Court orders otherwise after reviewing

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PORTER | SCOTT

The Final Pretrial hearing date (March 9, 2017) and date for commence of Jury Trial (May 8, 2017)

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

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and considering the above stipulation.

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IT IS SO STIPULATED.

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Dated: July 25, 2016

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PORTER SCOTT
A PROFESSIONAL CORPORATION
By/s/ Hovannes Nalbandyan
Steven E. Horan
Hovannes G. Nalbandyan
Attorneys for Defendant
CITY OF LINCOLN

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Dated: July 24, 2016

CENTER FOR DISABILITY ACCESS
By /s/ Amanda Lockhart (authorized)
Amanda Lockhart
Attorney for Plaintiff
RICHARD HAMMOND

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JOINT STIPULATION FOR CONTINUANCE OF PRE-TRIAL DATES AND ORDER

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ORDER

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Good cause appearing, PURSUANT TO THE STIPULATION, IT IS HEREBY

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ORDERED that the Pretrial Dates in this matter shall be continued as set forth in the stipulation

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above.

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Dated: July 28, 2016

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Troy L. Nunley
United States District Judge

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PORTER | SCOTT

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

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JOINT STIPULATION FOR CONTINUANCE OF PRE-TRIAL DATES AND ORDER