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

Filing 30

ORDER signed by District Judge Kimberly J. Mueller on 6/12/2017 ORDERING Discovery cut-off be extended solely for the purposes of completing the Rule30(b)(6) deposition noticed by Plaintiffs on 5/16/2017, this deposition will be completed by 7/28/201 7; Expert Disclosure by 8/15/2017, Supplemental expert disclosure by 9/15/2017; Expert discovery to 10/10/2017; Joint mid-litigation proposal deadline remain 9/28/2017; and mid-litigation conference remain on 10/12/2017 at 2:30 PM in Courtroom 3. (Reader, L)

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Jay T. Jambeck (SBN 226018)
Mandy G. Leigh (SBN 225748)
LEIGH LAW GROUP, P.C.
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

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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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,

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Case No.: 2:15-cv-00889-KJM-AC
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DISCOVERY
TIMELINES

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

_____/

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

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

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

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

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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. The following

dates were scheduled:

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a.

Discovery cut-off: March 31, 2017

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b.

Expert disclosure: April 2, 2017

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c.

Supplemental expert disclosure: May 2, 2017

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d.

Expert discovery cut-off: July 31, 2017

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e.

Joint mid-litigation proposal: August 31, 2017

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f.

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

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3.

On February 23, 2017, the parties stipulated to extend the above deadlines as

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follows:

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a.

Discovery cut-off be extended to May 31, 2017

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b.

Expert disclosure deadline be extended to July 28, 2017

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c.

Supplemental expert disclosure deadline be extended to August 31, 2017

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d.

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

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e.

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

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f.

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

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4.

On March 1, 2017, the Court entered an order approving the parties’ stipulated dates.

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5. Good cause exists to extend the dates set forth in the Court’s March 1, 2017

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

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several rounds of written discovery. Additionally, Defendant noticed and completed the

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depositions of thirteen of the Plaintiffs/parent representatives. Due to calendar conflicts and other

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scheduling issues, those depositions occurred over a period of several months and concluded on

STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
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May 19, 2017. Plaintiffs have noticed a Rule 30(b)(6) deposition to occur after the conclusion of

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the depositions of Plaintiffs but due to the complexity of the issues involved, along with the

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logistics of scheduling district employees responsive to the Rule 30(b)(6) categories at this time of

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year, additional time will be necessary for the Rule 30(b)(6) deposition to conclude within the

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present discovery schedule.

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6.

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

through their respective counsel of record that:
a.

Discovery cut-off be extended solely for the purposes of completing the Rule

30(b)(6) deposition noticed by Plaintiffs on May 16, 2017. This deposition will be
completed by July 28, 2017.

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b.

Expert disclosure deadline be extended to September 15, 2017.

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c.

Supplemental expert disclosure deadline be extended to October 13, 2017.

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d.

Expert discovery cut-off be extended to November 30, 2017.

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e.

Joint mid-litigation proposal deadline extended to December 7, 2017.

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f.

Mid-litigation status conference extended to December 14, 2017 at 2:30 pm.

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IT IS SO STIPULATED.

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DATED: May 31, 2017

LEIGH LAW GROUP, P.C.

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By:

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/s/ Jay T. Jambeck
_
________________________
Jay T. Jambeck
Attorneys for Plaintiffs

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DATED: May 31, 2017

SPINELLI, DONALD & NOTT
By:

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

_____________

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

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

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continue the dates set forth in the March 1, 2017 scheduling order is GRANTED. It is hereby

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ORDERED that:

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a.

Discovery cut-off be extended solely for the purposes of completing the Rule

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30(b)(6) deposition noticed by Plaintiffs on May 16, 2017. This deposition will be

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completed by July 28, 2017.

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b.

Expert disclosure deadline be extended to August 15, 2017.

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c.

Supplemental expert disclosure deadline be extended to September 15, 2017.

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d.

Expert discovery cut-off be extended to October 10, 2017.

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e.

Joint mid-litigation proposal deadline remain September 28, 2017.

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f.

Mid-litigation status conference remain on October 12, 2017 at 2:30 pm in

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Courtroom 3.
IT IS SO ORDERED.
DATED: June 12, 2017.

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UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER TO EXTEND DISCOVERY TIMELINE AND FURTHER STATUS CONFERENCE
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