W. C. v. Placer Hills Unified School District, et al

Filing 20

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/24/16 ORDERING that the non-expert discovery deadline shall be EXTENDED to 8/30/2016 for the purpose of taking the FRCP 30(b)(6) deposition noticed by Plaintiff for the reasons set forth in the accompanying Stipulation. (Mena-Sanchez, L)

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Mandy Leigh (SBN #225748)
Jay T. Jambeck (SBN #226018)
LEIGH LAW GROUP, P.C.
870 Market St., Suite 1157
San Francisco, CA 94102
Office: [phone]
Fax: [phone]
[e-mail]
[e-mail]

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION

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W.C. BY AND THROUGH HIS MOTHER,
C.M.,
Plaintiff(s),

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v.
PLACER HILLS UNION SCHOOL DISTRICT,
STEVE SCHAUMLEFFEL,
Defendant(s).

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Case No.: 2:15-cv-00716-TLN-CKD
STIPULATION AND ORDER TO
EXTEND THE NON-EXPERT
DISCOVERY DEADLINE FOR THE
PURPOSE OF TAKING A FRCP
30(b)(6) DEPOSITION
Magistrate Judge Carolyn K. Delaney
Complaint Filed: March 30, 2015
1st Amend. Comp. Filed: June 8, 2015
Trial Date: May 15, 2017

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THE PARTIES TO THIS MATTER, by and through their respective attorneys of record

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herein, do hereby stipulate and agree that the non-expert discovery deadline of June 27, 2016 be

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extended to August 30, 2016 for the purpose of completing one deposition that was noticed

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pursuant to Federal Rule of Civil Procedure 30(b)(6) of Defendant PLACER HILLS UNION

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SCHOOL DISTRICT. The basis for the extension is as follows:

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1. Plaintiff noticed the FRCP deposition for June 22, 2016. Defendant has identified three

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witnesses that it intends to designate to testify as to certain categories set forth by

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Plaintiff. However, only two of the witnesses were available on June 22, 2016. A third

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witness was available June 24, 2016, but counsel for Plaintiff was scheduled to be in

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hearing in San Francisco on that date.

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Stipulation to Extend Discovery; Order Thereon – Page 1

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2. On June 21 and 22, Defendants took depositions of Plaintiff W.C. and his mother C.M.

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along with designated witnesses from the Placer County Department of Education. At

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that time, counsel met and conferred and determined that, since a mediation is

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scheduled on August 16, 2016 before Patricia Tweedy, Esq., time and expense might be

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spared in continuing out the deadline for the FRCP 30(b)(6) deposition until after the

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mediation.

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3. Expert designations are not due in this matter until August 30, 2016. Dispositive
motions must be heard by December 8, 2016 and the trial date is May 15, 2017.

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4. Therefore, the parties proposed new non-expert discovery deadline – solely for the

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purposes of the FRCP 30(b)(6) deposition – of August 30, 2016 does not interfere with

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expert discovery, which only can start after August 30, 2016, or with the timing of

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dispositive motions or trial.

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5. The parties previously sought by stipulation filed February 12, 2016 a continuance of

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the trial date due to the schedule of Defendant STEVE SCHAUMLEFFEL along with

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the extension of other deadlines, including non-expert discovery. The Court approved

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the stipulation on February 19, 2016 and ordered the trial continuance and

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corresponding extensions to the dates set forth above.

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6. The extension requested will not delay the trial or impact any other deadline presently
set in this action.

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Dated: June 23, 2016

JACOBSON, HANSEN & McQUILLAN
/s/ Leith B. Hansen
By:
LEITH B. HANSEN, Attorneys for
Defendants, PLACER HILLS UNIFIED
SCHOOL DISTRICT, sued herein as PLACER
HILLS UNION SCHOOL DISTRICT and
STEVE SCHAUMLEFFEL

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Stipulation to Extend Discovery; Order Thereon – Page 2

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Dated: June ____, 2016

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LEIGH LAW GROUP, P.C.

/s/ Jay T. Jambeck
By:
JAY T. JAMBECK, Attorneys for Plaintiff,
W.C., by and through his Mother, C.M.

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ORDER

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IT IS HEREBY ORDERED that the non-expert discovery deadline shall be extended to

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August 30, 2016 for the purpose of taking the Federal Rule of Civil Procedure 30(b)(6) deposition

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noticed by Plaintiff for the reasons set forth in the accompanying Stipulation.

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Dated: June 24, 2016

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Troy L. Nunley
United States District Judge

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Stipulation to Extend Discovery; Order Thereon – Page 3