Shannon v. County of Sacramento
Filing
131
STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 8/17/2021 ORDERING that Defendants shall be permitted to designate David M. Blake as their replacement police practices / use of force expert for Joe Callanan. Defendants sh all file their Disclosure of Replacement Police Practices / Use of Force Expert Witness Information within ten days of the entry of this order. Defendants shall pay Mr. Blake's hourly fee for up to two hours of deposition testimony and shall pay for plaintiff's copy of the deposition transcript. (Zignago, K.)
Case 2:15-cv-00967-KJM-DB Document 131 Filed 08/17/21 Page 1 of 3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
RIVERA HEWITT PAUL LLP
JONTHAN B. PAUL, SBN 215884
WENDY MOTOOKA, SBN 233589
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
Tel: 916-922-1200 Fax: 916 922-1303
Email: JPaul@rhplawyers.com
wmotooka@rhplawyers.com
Attorneys for Defendants TIMOTHY JONES and
JOSEPH REEVE
GARY W. GORSKI (SBN 166526)
LAW OFFICES OF GARY W. GORSKI
3017 DOUGLAS BLVD. SUITE 150
ROSEVILLE, CA 95661
916-758-1100
CIVILRIGHTSATTORNEY@OUTLOOK.COM
WWW.LONEWOLFLAW.COM
DANIEL M. KARALASH (SBN 176422)
STRATEGIC LAW COMMAND
3017 DOUGLAS BLVD. SUITE 150
ROSEVILLE, CA 95661
(916) 787-1234
DAN@STRATLAW.ORG
WWW.STRATLAW.COM
Attorneys for PLAINTIFF,
SALVADOR SHANNON, an individual
18
UNITED STATES DISTRICT COURT
19
EASTERN DISTRICT OF CALIFORNIA
20
21
22
SALVADOR SHANNON, as an individual
and as a successor in interest to RYAN
SHANNON,
23
24
25
26
27
28
RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
(916) 922-1200
Plaintiff,
vs.
COUNTY OF SACRAMENTO, a
government entity, TIMOTHY JONES, an
individual; and JOSEPH REEVE, an
individual,
No.: 2:15-CV-00967 KJM DB
STIPULATION TO ALLOW
DEFENDANTS’ DESIGNATION OF A
REPLACEMENT POLICE PRACTICES /
USE OF FORCE EXPERT; ORDER
THEREON
Defendants.
STIPULATION TO ALLOW DEF.S’ DESIGNATION OF
REPLACEMENT EXPERT
Case No. 2:15-CV-00967 KJM DB
1
Case 2:15-cv-00967-KJM-DB Document 131 Filed 08/17/21 Page 2 of 3
1
2
WHEREAS, pursuant to the modified scheduling order of November 3, 2016 (Doc. 58),
3
defendants disclosed their expert witnesses in this case on July 3, 2017, including police practices
4
/ use of force expert Joe Callanan of Callanan & Associates;
5
6
WHEREAS Mr. Callanan notified defense counsel in December 2020 of his need to
withdraw from this case for medical reasons (see attached Exhibit A);
7
8
9
10
WHEREAS defendants began to search for a replacement police practices / use of force
expert;
WHEREAS, while defendants were searching for a replacement police practices / use of
force expert, the parties were referred to a settlement conference set for June 24, 2021;
11
WHEREAS the settlement conference was unsuccessful;
12
WHEREAS defendants then retained a replacement police practices /use of force expert,
13
David M. Blake, who completed a written report on July 13, 2021;
14
WHEREAS on July 15, 2021, defense counsel initiated a meet and confer with plaintiff’s
15
counsel regarding defendants’ proposed designation of Mr. Blake as a replacement expert for Mr.
16
Callanan;
17
WHEREAS on July 29, 2021, plaintiff’s counsel stated that they would not oppose the
18
designation of Mr. Blake as a replacement expert, if defendants would pay Mr. Blake’s fee for
19
two hours of deposition and cover the cost of plaintiff’s copy of the deposition transcript;
20
WHEREAS, defendants agree to plaintiff’s proposal;
21
22
23
24
THEREFORE, the parties now hereby stipulate, through their counsel of record, as
follows:
1.
Defendants shall be permitted to designate David M. Blake as their police
25
practices /use of force expert in place of Joe Callanan, by filing the proposed Defendants’
26
Disclosure of Replacement Police Practices / Use of Force Expert Witness Information (attached
27
hereto as Exhibit B);
28
RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
(916) 922-1200
2.
Defendants will pay for up to two hours of Mr. Blake’s time at deposition and will
STIPULATION TO ALLOW DEF.S’ DESIGNATION OF
REPLACEMENT EXPERT
Case No. 2:15-CV-00967 KJM DB
2
Case 2:15-cv-00967-KJM-DB Document 131 Filed 08/17/21 Page 3 of 3
1
2
also pay for plaintiff’s copy of the deposition transcript.
IT IS SO STIPULATED.
3
4
DATE: August 5, 2021
RIVERA HEWITT PAUL LLP
5
/s/ Wendy Motooka
JONATHAN B. PAUL
WENDY MOTOOKA
Attorneys for Defendants TIMOTHY JONES and
JOSEPH REEVE
6
7
8
9
10
Dated: August 4, 2021
11
/s/ Gary W. Gorski (as authorized on 8-4-21)
Gary W. Gorski
Attorney for Plaintiff
12
13
14
ORDER
15
16
17
18
19
20
21
22
23
24
25
After considering the Stipulation by and between the parties through their counsel of
record and good cause appearing, IT IS HEREBY ORDERED THAT:
1.
Defendants shall be permitted to designate David M. Blake as their replacement
police practices / use of force expert for Joe Callanan;
2.
Defendants shall file their Disclosure of Replacement Police Practices / Use of
Force Expert Witness Information within ten days of the entry of this order; and
3.
Defendants shall pay Mr. Blake’s hourly fee for up to two hours of deposition
testimony and shall pay for plaintiff’s copy of the deposition transcript.
IT IS SO ORDERED.
DATE: August 17, 2021.
26
27
28
RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
(916) 922-1200
STIPULATION TO ALLOW DEF.S’ DESIGNATION OF
REPLACEMENT EXPERT
Case No. 2:15-CV-00967 KJM DB
3
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?