T.V. et al v. Sacramento City Unified School District

Filing 27

STIPULATION AND ORDER signed by District Judge Kimberly J. Mueller on 3/1/2017 ORDERING: Discovery cut-off is EXTENDED to 5/31/2017; Designation of Expert Witnesses is EXTENDED to 7/28/2017; Supplemental expert disclosure deadline is EXTENDED to 8/31 /2017; Expert discovery cut-off is EXTENDED to 9/22/2017; Joint mid-litigation proposal filing deadline is EXTENDEDto 9/28/2017; and the Status Conference CONTINUED to 10/12/2017 at 02:30 PM in Courtroom 3 (KJM) before District Judge Kimberly J. Mueller. (Washington, S)

1
2
3
4
5
6
7
8
9
10
11
12

Jay T. Jambeck (SBN 226018)
Mandy G. Leigh (SBN 225748)
LEIGH LAW GROUP
870 Market Street, Suite 1157
San Francisco, CA 94102
Telephone: [phone]
Facsimile:
415-795-3733
Attorneys for Plaintiffs
SPINELLI, DONALD & NOTT
A Professional Corporation
Domenic D. Spinelli (SBN: 131192)
Alison W. Winter (SBN: 251084)
815 S Street, Second Floor
Sacramento, CA 95811
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Sacramento City Unified School District

13
IN THE UNITED STATES DISTRICT COURT

14

FOR THE EASTERN DISTRICT OF CALIFORNIA

15
16
17
18
19
20
21
22

T.V. and A.V. by and through their guardians
Will Valerio and Jackie Valerio, and Will
Valerio and Jackie Valerio, individually, D.S.
by and through her guardian Arthur Aleman,
I.M. and I.M. by and through their guardians
Jorge Maranon and Isabella Maranon, Jorge
Maranon and Isabella Maranon individually,
D.S. by and through his guardians Adrian
Sanchez and Stephanie Sanchez, J.S. by and
through David Schnetz and Amy Schnetz,
A.S. by and through her guardian Stacey
Swett,

23
24
25
26
27

Case No.: 2:15-cv-00889-KJM-AC
STIPULATION AND TO EXTEND
DISCOVERY TIMELINE AND
FURTHER STATUS CONFERENCE

Plaintiffs,
vs.
SACRAMENTO CITY UNIFIED SCHOOL
DISTRICT,
Defendant.
___________________________

_____/

28

STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
1

STIPULATION

1
2

Pursuant to Federal Rule of Civil Procedure 16, Plaintiffs, through their attorneys of record,

3

and Defendant, through its attorneys of record, hereby request that the Court modify the current

4

Scheduling Order and extend the discovery and expert disclosure deadlines as follows:

5
6
7

1.

On February 2, 2016, the parties attended an initial scheduling conference. The

Court’s Status (Pretrial Scheduling) Order was filed on February 12, 2016 as Docket Number 23.
2.

On February 17, 2016, Plaintiffs filed a Third Amended Complaint. On June 11,

8

2015, Plaintiffs filed a First Amended Complaint (“FAC”) with this Court. The following dates

9

were scheduled:

10

a.

Discovery cut-off: March 31, 2017

11

b.

Expert disclosure: April 2, 2017

12

c.

Supplemental expert disclosure: May 2, 2017

13

d.

Expert discovery cut-off: July 31, 2017

14

e.

Joint mid-litigation proposal: August 31, 2017

15

f.

Mid-litigation status conference: September 14, 2017 at 2:30 pm

16

3.

Good cause exists to extend the dates set forth in the Court’s February 12, 2016

17

Scheduling Order. The parties have worked diligently to complete discovery, including undertaking

18

written discovery. The parties are also in the process of completing depositions. However, due to

19

the complexity of this case, including the number of Plaintiffs and their Guardians ad Litem, it is

20

not feasible to complete all requisite depositions by March 31, 2017, including the District

21

employee depositions, and provide those deposition transcripts to retained experts for their review,

22

analysis, and incorporation into their reports by the next day, April 1, 2017.

23
24
25
26

4.

There are currently dates scheduled for dispositive motions or trial that would need

to be altered.
5.

Based on the foregoing, IT IS HEREBY STIPULATED, by and between all parties

through their respective counsel of record that:

27

a.

Discovery cut-off be extended to May 31, 2017

28

b.

Expert disclosure deadline be extended to July 28, 2017

STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
2

1

c.

Supplemental expert disclosure deadline be extended to August 31, 2017

2

d.

Expert discovery cut-off be extended to September 22, 2017

3

e.

Joint mid-litigation proposal deadline be extended to September 28, 2017

4

f.

Mid-litigation status conference be continued to October 12, 2017 at 2:30 pm

5

IT IS SO STIPULATED.

6
7

DATED: February 23, 2017

LEIGH LAW GROUP

8

By:

9
10

/s/ Jay Jambeck
Jay Jambeck
Nathan Sullivan
Attorneys for Plaintiffs

11
12
13
14
15
16

DATED: February 23, 2017

SPINELLI, DONALD & NOTT
By:

/s/ Domenic D. Spinelli
Domenic D. Spinelli
Alison W. Winter.
Attorneys for Defendant

17
18
19
20
21
22
23
24
25
26
27
28

STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
3

ORDER

1
2

Pursuant to the stipulation of the parties, and for good cause shown thereby, the request to

3

continue the dates set forth in the February 12, 2016 Status (Pretrial Scheduling) is GRANTED. It

4

is hereby ORDERED that:

5

a.

The discovery cut-off is extended to May 31, 2017;

6

b.

The expert disclosure deadline is extended to July 28, 2017;

7

c.

The supplemental expert disclosure deadline is extended to August 31, 2017;

8

d.

The expert discovery cut-off is extended to September 22, 2017;

9

e.

The joint mid-litigation proposal filing deadline is extended to September 28, 2017;

10

f.

A mid-litigation status conference will be held on October 12, 2017 at 2:30 pm in

11
12
13

Courtroom 3.
IT IS SO ORDERED.
Dated: March 1, 2017

14
15
16

UNITED STATES DISTRICT JUDGE

17
18
19
20
21
22
23
24
25
26
27
28

STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
4