Glynn v. City of Stockton

Filing 77

STIPULATION AND ORDER signed by District Judge Kimberly J. Mueller on 10/14/2016 ORDERING the plaintiff to produce any additional/supplemental documentation on wage loss mitigation by 10/31/2016; ORDERING the parties to file and serve any supplemenatal expert report(s) by their previously disclosed expert(s) by 11/10/2016; ORDERING that supplemental expert discovery be completed by 11/30/2016; ORDERING the parties to supplement their Trial Exhibit Lists by 12/9/2016. (Michel, G.)

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GARY R. BASHAM (SBN 130119)
NANCY L. McCOY (SBN 184983)
BASHAM LAW GROUP
100 Pringle Avenue, Suite 330
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff,
JESSICA GLYNN

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JESSE J. MADDOX (SBN 219091)
KIMBERLY A. HORIUCHI (SBN 214869)
LIEBERT CASSIDY WHITMORE
5250 N. Palm Avenue, Suite 310
Fresno, CA 93704
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
CITY OF STOCKTON

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JESSICA GLYNN, an individual,

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Case No. 2:15-CV-00529-KJM-JB

Plaintiff,
v.

STIPULATION AND ORDER RE:
EXPERT DISCOVERY
.
Judge: Hon Kimberly Mueller
Courtroom 3, 15th Floor
Trial Date: January 30, 2017

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CITY OF STOCKTON; and DOES 1
through 50, inclusive,
Defendants.

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Pursuant to this Court’s September 9, 2016 Minute Order (ECF #56), Plaintiff

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JESSICA GLYNN and Defendant CITY OF STOCKTON, through their counsel of record,

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submitted a Joint Stipulation Re: Status Of Meet And Confer Efforts Of Counsel Relating To

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Expert Discovery (ECF #59) on September 16, 2016.
STIPULATION AND ORDER RE: EXPERT
DISCOVERY

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Case No. 2:15-CV-00529-KJM-JB

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This Court’s Final Pretrial Order issued on September 22, 2016 (ECF #60) further

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directed the parties to meet and confer to determine how they wished to proceed with regard to

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the outstanding expert discovery issues, and submit a stipulation and proposed order by October

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21, 2016.

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Following meet and confer efforts, counsel for the parties have stipulated to, and
hereby jointly propose to the Court, the following updated expert discovery schedule:

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Activity 
Deadline for Plaintiff to produce any
additional/supplemental documentation on wage loss
mitigation (not including supplemental expert reports).

Proposed Revised Deadline date
10/31/16 

Deadline for the parties to file and serve any supplemental 11/10/16 
expert report(s) by their previously disclosed expert(s).
The parties may not, however, designate additional or
different experts.

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Deadline for completion of supplemental expert
discovery.

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11/30/16 

Deadline for the parties to supplement their Trial Exhibit
Lists with regard to any documents produced by Plaintiff
regarding wage loss/mitigation, and any supplemental
expert reports.

12/9/16 

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Date: October 10, 2016

BASHAM LAW GROUP

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By:

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/s/Nancy L. McCoy
NANCY L. McCOY
Attorneys for Plaintiff
Jessica Glynn

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Date: October 10, 2016

LIEBERT CASSIDY WHITMORE

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By: /s/ Jesse Maddox
JESSE MADDOX
KIMBERLY HORIUCHI
Attorneys for Defendant
City of Stockton

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STIPULATION AND ORDER RE: EXPERT
DISCOVERY

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Case No. 2:15-CV-00529-KJM-JB

ORDER

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Having read and considered the parties’ Stipulation Re: Expert Discovery, and good cause

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appearing, IT IS HEREBY ORDERED THAT the expert discovery schedule in this case shall be

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modified as follows:

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Activity 

Revised Deadline date

Deadline for Plaintiff to produce any additional/supplemental
documentation on wage loss mitigation (not including supplemental
expert reports).

10/31/16 

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Deadline for the parties to file and serve any supplemental expert
11/10/16 
report(s) by their previously disclosed expert(s). The parties may not,
however, designate additional or different experts.

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Deadline for completion of supplemental expert discovery.

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Deadline for the parties to supplement their Trial Exhibit Lists with
regard to any documents produced by Plaintiff regarding wage
loss/mitigation, and any supplemental expert reports.

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11/30/16 
12/9/16 

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IT IS SO ORDERED.
Dated: October 14, 2016

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UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER RE: EXPERT
DISCOVERY

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Case No. 2:15-CV-00529-KJM-JB