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
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RIVERA HEWITT PAUL LLP
JONTHAN B. PAUL, SBN 215884
WENDY MOTOOKA, SBN 233589
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
Tel: [phone] Fax: [phone]
Email: [e-mail]
[e-mail]
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
[e-mail]
WWW.LONEWOLFLAW.COM
DANIEL M. KARALASH (SBN 176422)
STRATEGIC LAW COMMAND
3017 DOUGLAS BLVD. SUITE 150
ROSEVILLE, CA 95661
[phone]
[e-mail]
WWW.STRATLAW.COM
Attorneys for PLAINTIFF,
SALVADOR SHANNON, an individual

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SALVADOR SHANNON, as an individual
and as a successor in interest to RYAN
SHANNON,

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RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
[phone]

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

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Case 2:15-cv-00967-KJM-DB Document 131 Filed 08/17/21 Page 2 of 3
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WHEREAS, pursuant to the modified scheduling order of November 3, 2016 (Doc. 58),

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defendants disclosed their expert witnesses in this case on July 3, 2017, including police practices

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/ use of force expert Joe Callanan of Callanan & Associates;

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WHEREAS Mr. Callanan notified defense counsel in December 2020 of his need to
withdraw from this case for medical reasons (see attached Exhibit A);

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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;

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WHEREAS the settlement conference was unsuccessful;

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WHEREAS defendants then retained a replacement police practices /use of force expert,

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David M. Blake, who completed a written report on July 13, 2021;

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WHEREAS on July 15, 2021, defense counsel initiated a meet and confer with plaintiff’s

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counsel regarding defendants’ proposed designation of Mr. Blake as a replacement expert for Mr.

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Callanan;

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WHEREAS on July 29, 2021, plaintiff’s counsel stated that they would not oppose the

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designation of Mr. Blake as a replacement expert, if defendants would pay Mr. Blake’s fee for

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two hours of deposition and cover the cost of plaintiff’s copy of the deposition transcript;

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WHEREAS, defendants agree to plaintiff’s proposal;

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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

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practices /use of force expert in place of Joe Callanan, by filing the proposed Defendants’

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Disclosure of Replacement Police Practices / Use of Force Expert Witness Information (attached

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hereto as Exhibit B);

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RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
[phone]

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

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Case 2:15-cv-00967-KJM-DB Document 131 Filed 08/17/21 Page 3 of 3
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also pay for plaintiff’s copy of the deposition transcript.
IT IS SO STIPULATED.

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DATE: August 5, 2021

RIVERA HEWITT PAUL LLP

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/s/ Wendy Motooka
JONATHAN B. PAUL
WENDY MOTOOKA
Attorneys for Defendants TIMOTHY JONES and
JOSEPH REEVE

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Dated: August 4, 2021

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/s/ Gary W. Gorski (as authorized on 8-4-21)
Gary W. Gorski
Attorney for Plaintiff

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ORDER

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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.

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RIVERA HEWITT PAUL LLP
11341 Gold Express Drive, Suite 160
Gold River, CA 95670
[phone]

STIPULATION TO ALLOW DEF.S’ DESIGNATION OF
REPLACEMENT EXPERT
Case No. 2:15-CV-00967 KJM DB

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