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

Filing 22

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 8/16/16 ORDERING that the Expert Discovery shall be EXTENDED to 9/30/2016 and the deadline for supplemental expert disclosure shall be EXTENDED to 10/20/2016. (Mena-Sanchez, L)

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Leith B. Hansen, No. 109320
JACOBSON, HANSEN & McQUILLAN
A Professional Corporation
1690 W. Shaw Avenue, Suite 201
Fresno, California 93711
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants, PLACER HILLS UNION SCHOOL DISTRICT and STEVE
SCHAUMLEFFEL

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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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Case No.: 2:15-cv-00716-TLN-CKD
STIPULATION AND ORDER TO
EXTEND EXPERT DISCOVERY
DEADLINES

v.
PLACER HILLS UNION SCHOOL DISTRICT,
STEVE SCHAUMLEFFEL,

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Magistrate Judge Carolyn K. Delaney
Complaint Filed: March 30, 2015
1st Amend. Comp. Filed: June 8, 2015
Trial Date: May 15, 2017

Defendant(s).

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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 expert witness disclosure deadline of August 30,

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2016 be extended to September 30, 2016, and the supplemental expert disclosure deadline of

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September 20, 2016 be extended to October 20, 2016. The basis for the extension is as follows:

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1.

The parties have stipulated to an Independent Psychiatric Examination of plaintiff

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W.C. to be conducted by Dr. Anlee Kuo, MD. The date set for the Independent Psychiatric

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Examination, by agreement of the parties, is August 24, 2016. Additionally, plaintiff plans to

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complete non-expert, person most knowledgeable depositions by August 30, 2016, pursuant to a

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prior, stipulated order of this court. The present expert designation date does not permit Dr. Kuo

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an adequate period of time to report on her Independent Psychiatric Examination and, if necessary,

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on the results of the non-expert depositions.
Stipulation and Order to Extend Expert Discovery Deadlines – Page 1

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2.

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15, 2017.

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Dispositive motions must be heard by December 8, 2016, and the trial date is May

Therefore, the parties’ proposed new expert discovery deadlines do not interfere

with the timing of dispositive motions or trial.

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4.

The parties previously sought and obtained by stipulation dated February 12, 2016,

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a continuance of the trial date due to the scheduled vacation of defendant STEVE

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SCHUAMLEFFEL, along with the extension of other deadlines, including expert discovery. The

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Court approved 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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5.

The parties also previously sought and obtained by stipulation dated June 23, 2016,

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a continuance of the non-expert discovery deadline due to difficulties in timely scheduling the

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deposition of persons most knowledgeable at defendant School District. The Court approved that

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stipulation on June 24, 2016, and ordered the extension of the non-expert discovery deadline from

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June 27, 2016 to August 30, 2016.

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supplemental expert disclosure were unaffected by that stipulation.

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6.

The deadlines for disclosure of expert witnesses and

The extension requested will not delay the trial or impact any other deadlines

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presently set in this action.

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IT IS SO STIPULATED.

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Dated: August 15, 2016

LEIGH LAW GROUP

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By: /S/ Jay T. Jambeck__
JAY T. JAMBECK, Attorneys for Plaintiff,
W.C. by and through his mother C.M.

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Stipulation and Order to Extend Expert Discovery Deadlines – Page 2

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IT IS SO STIPULATED.

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Dated: August ____, 2016

JACOBSON, HANSEN & McQUILLAN

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By: /S/ Leith B. Hansen__
LEITH B. HANSEN, Attorneys for
Defendants, PLACER HILLS UNION
SCHOOL DISTRICT and STEVE
SCHAUMLEFFEL

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ORDER

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

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September 30, 2016 and the deadline for supplemental expert disclosure shall be extended to

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October 20, 2016 for the reasons set forth in the accompanying stipulation.

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Dated: August 16, 2016

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Troy L. Nunley
United States District Judge

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Stipulation and Order to Extend Expert Discovery Deadlines – Page 3