Hugunin et al v. Rocklin Unified School District et al

Filing 105

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 1/5/17: Fact discovery cutoff is continued to June 30, 2017. Expert disclosure deadline is continued to September 30, 2017. The last day to file dispositive motions is continued to December 29, 2017. The deadline to file dispositive motions is continued to The Settlement Conference date remains unchanged. (Kaminski, H)

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Peter W. Alfert, SBN 83139
HINTON ALFERT, PC
200 Pringle Ave., Suite 450
Walnut Creek, California 94596
Telephone: [phone]
Facsimile: [phone]

Todd Boley, SBN 68119
Zoya Yarnykh, SBN 258062
LAW OFFICE OF TODD BOLEY
2381 Mariner Square Drive, Suite 280
Alameda, CA 94501
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiffs JENNIFER
HUGUNIN, PATRICK HUGUNIN, D.H., KEITH
CALDWELL, NICOLE HILL, X.C., TRISHA PITTS,
CARL PITTS, and N.P.
Gregory P. O’Dea, SBN 110966
Mark P. O’Dea, SBN 186061
Natasha N. Langenfeld, SBN 250944
LONGYEAR, O’DEA & LAVRA, LLP
3620 American River Drive, Suite 230
Sacramento, CA 95864
Phone: [phone]
Facsimile: 916-974-8510
Attorneys for Defendant, SHERRY MCDANIEL

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Carol A. Wieckowski, Esq., SBN 95586
Cathleen J. Fralick, Esq., SBN 146378
EVANS, WIECKOWSKI, WARD &
SCOFFIELD, LLP
745 University Avenue, Sacramento, CA 95825
Telephone: [phone]
Attorneys for Defendants
ROCKLIN UNIFIED SCHOOL DISTRICT,
CHARLES THIBIDEAU, BETTY JO WESSINGER,
JANNA CAMBRA, KEVIN BROWN, ROGER
STOCK and DR. TODD CUTLER

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JENNIFER HUGUNIN, PATRICK
)
HUGUNIN, D.H., a minor by and through his )
guardian ad litem JENNIFER HUGUNIN;
)
KEITH CALDWELL, NICOLE HILL, X.C. )
a minor by and through his guardian ad litem )
KEITH CALDWELL; TRISHIA PITTS,
)
CARL PITTS, N.P., a minor by and through )
his guardian ad litem TRISHIA PITTS; TODD )
VROOMAN, LAURA VROOMAN, S.V., a )
minor by and through his guardian ad litem
)
TODD VROOMAN; RICHARD ROGERS, )
TERRILL ROGERS, P.R, a minor by and
)
through his guardian ad litem RICHARD
)
ROGERS; MICHELLE MANCOUR and G.I., )
a minor by and through his guardian ad litem )
MICHELLE MANCOUR,
)
Plaintiffs,)
vs.
)
)
ROCKLIN UNIFIED SCHOOL DISTRICT )
SHERRY MCDANIEL, CHARLES
)
THIBIDEAU, BETTY JO WESSINGER,
)
JANNA CAMBRA, KEVIN BROWN,
)
ROGER STOCK, DR. TODD CUTLER, and )
Does 1-30, Inclusively,
)
Defendants.)
)

CASE NO. 2:15-CV-00939-MCE-DB
AMENDED STIPULATION AND ORDER RE:
REVISING OF PRETRIAL SCHEDULING
ORDER

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Amended Stipulation to Revise Pretrial Scheduling Order
Page 1
2:15-CV-00939-MCE-DB

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This Stipulation is entered into by and between plaintiffs, TRISHIA PITTS, CARL PITTS, N.P., a

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minor by and through his guardian ad litem TRISHIA PITTS, by and through their counsel Peter W.

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Alfert, of Hinton Alfert PC, and Todd Boley and Zoya Yarnykh of Boley Law; and defendants,

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ROCKLIN UNIFIED SCHOOL DISTRICT CHARLES THIBIDEAU, BETTY JO WESSINGER,

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JANNA CAMBRA, KEVIN BROWN, ROGER STOCK, and DR. TODD CUTLER, by and through their

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counsel, Carol Wieckowski of Evans, Wieckowski, Ward & Scoffield; and defendant SHERRY

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McDANIEL, by and through her counsel, Gregory P. O’Dea and Natasha Langenfeld of Longyear, O’Dea

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& Lavra, LLP.

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The parties to this action hereby stipulate, by and through their respective undersigned counsel of
record, as follows:
WHEREAS, the initial Pretrial Scheduling Order (Doc. 40) was previously modified on June 30,

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2016, thereby extending fact discovery cut-off from October 17, 2016 to February 28, 2017. Expert

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discovery was extended to be completed by May 31, 2017, from the initial date of December 16, 2016

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(See Doc. 91). “Completed” means that all discovery shall have been conducted so that all depositions

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have been taken and all disputes relative to discovery shall have been resolved. The parties stipulate that

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they will not be able to conduct all discovery needed by the current cutoff date due to potential additional

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plaintiffs (Doc. 79, motion currently pending), and there has been no discovery with respect to these

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proposed new plaintiffs. This Court, on its own motion, has taken this matter off trial calendar on

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November 2, 2016 (Doc. 96, text-only Minute Order).

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Parties propose June 30, 2017 as a fact discovery cutoff date. Plaintiffs have been diligently

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responding to and pursuing discovery, and have engaged in numerous meet and confer efforts with

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defense counsel through letters and conference calls. Some depositions have been taken and completed,

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yet several remain outstanding, of both witnesses and Defendants, including Sherry McDaniel.

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WHEREAS, the current expert disclosure deadline is May 31, 2017. The parties, in light of the

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requested fact discovery cutoff date, stipulate to continue the expert disclosure deadline accordingly, to

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September 29, 2017.

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WHEREAS, the current last day to hear dispositive motions is April 13, 2017 (See Doc. 40). The
parties, in light of the requested discovery cutoff dates above, stipulate to continue the last day to hear
______________________________________________________________________________________________________
Amended Stipulation to Revise Pretrial Scheduling Order
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2:15-CV-00939-MCE-DB

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dispositive motions to December 29, 2017.
WHEREAS, a Settlement Conference is currently set for December 22, 2016 before the Honorable

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Edmund F. Brennan. The parties believe that this Settlement Conference may prove to be productive,

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given the current state of discovery, as well as the resolution of all of the Plaintiffs’ cases except for the

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Pitts family, the only remaining active Plaintiffs in this matter.

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The parties therefore respectfully request that the Court enter a Revised Pretrial Scheduling Order

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reflecting those dates.

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IT IS SO STIPULATED:

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Dated: 12/6/16

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HINTON ALFERT, PC
By: ____/s/_______________________________
PETER W. ALFERT
Attorney for Plaintiffs, JENNIFER HUGUNIN,
PATRICK HUGUNIN, D.H., a minor by and
through his guardian ad litem JENNIFER
HUGUNIN; KEITH CALDWELL, NICOLE
HILL, X.C. a minor by and through his guardian ad
litem KEITH CALDWELL; TRISHIA PITTS,
CARL PITTS, N.P., a minor by and through his
guardian ad litem TRISHIA PITTS

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Dated: 12/6/16

By: ____/s/____________________________
TODD BOLEY
Attorney for Plaintiffs, JENNIFER HUGUNIN,
PATRICK HUGUNIN, D.H., a minor by and
through his guardian ad litem JENNIFER
HUGUNIN; KEITH CALDWELL, NICOLE
HILL, X.C. a minor by and through his guardian ad
litem KEITH CALDWELL; TRISHIA PITTS,
CARL PITTS, N.P., a minor by and through his
guardian ad litem TRISHIA PITTS

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LAW OFFICES OF TODD BOLEY

Dated: 12/6/16

EVANS, WIECKOWSKI, WARD & SCOFFIELD, LLP
By: ___/s/_____________________________
CAROL WIECKOWSKI
Attorney for Defendants,
ROCKLIN UNIFIED SCHOOL DISTRICT
CHARLES THIBIDEAU, BETTY JO
WESSINGER, JANNA CAMBRA, KEVIN

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Amended Stipulation to Revise Pretrial Scheduling Order
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2:15-CV-00939-MCE-DB

BROWN, ROGER STOCK, and DR. TODD
CUTLER

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Dated: 12/6/16

LONGYEAR, O’DEA & LAVRA, LLP
By: _____/s/___________________________
GREGORY P. O’DEA
NATASHA LANGENFELD
Attorney for Defendant,
SHERRY MCDANIEL

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ORDER

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Pursuant to the stipulation of the parties, and good cause appearing, it is hereby ordered as follows:

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Fact discovery cutoff is continued to June 30, 2017. Expert disclosure deadline is continued to

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September 30, 2017. The last day to file dispositive motions is continued to December 29, 2017. The

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deadline to file dispositive motions is continued to The Settlement Conference date remains unchanged.

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IT IS SO ORDERED.
Dated: January 5, 2017

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______________________________________________________________________________________________________
Amended Stipulation to Revise Pretrial Scheduling Order
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2:15-CV-00939-MCE-DB