Shannon v. County of Sacramento

Filing 135

ORDER signed by Chief District Judge Kimberly J. Mueller on 10/5/2022 ORDERING Final Pretrial Conference RESCHEDULED to 2/11/2022 at 10:00 AM, which is at least 60 days after the date of the expert witness' deposition, hearing in Courtroom 3 (KJM) before Chief District Judge Kimberly J. Mueller. Joint Pretrial Statement shall be CONTINUED to 1/21/2022. (Reader, L)

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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
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

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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,
Plaintiff,

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vs.

No.: 2:15-CV-00967 KJM DB
STIPULATION TO CONTINUE FINAL
PRE-TRIAL CONFERENCE; ORDER
THEREON

COUNTY OF SACRAMENTO, a
government entity, TIMOTHY JONES, an
individual; and JOSEPH REEVE, an
individual,
Defendants.

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STIPULATION AND ORDER
Case No. 2:15-CV-00967 KJM DB

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WHEREAS, defendants retained a replacement police practices /use of force expert,
David M. Blake, who completed a written report on July 13, 2021;

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WHEREAS on August 17, 2021 at docket entry #131, a STIPULATION and ORDER was

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signed by Chief District Judge Kimberly J. Mueller on 8/17/2021 ORDERING that Defendants

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shall be permitted to designate David M. Blake as their replacement police practices / use of force

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expert for Joe Callanan, subject to the conditions stipulated to by the parties;

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WHEREAS on August 27, 2021, defendants filed their DESIGNATION/DISCLOSURE
of EXPERT WITNESS by Timothy Jones, Joseph Reeve.

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WHEREAS the parties met and conferred on available deposition dates, and agreed upon
November 17, 2021 being the expert’s deposition date.

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WHEREAS at the time the parties agreed upon a date, there was no trial date or pre-trial
conference scheduled.

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WHEREAS on September 22, 2021, this Court issued a minute order stating that a “Final

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Pretrial Conference is SET for 10/29/2021,” with a Joint Pretrial Statement due by October 8,

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2021 (Doc. 133).

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WHEREAS the Court’s Pretrial Scheduling Order (Doc. 54) requires the parties, in the

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Joint Pretrial Statement, to jointly list undisputed and disputed core facts that are relevant to each

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claim.

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WHEREAS on September 30, 2021, the parties met and conferred to prepare the Joint

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Pretrial Statement, and concluded that the undisputed and disputed core facts cannot fully be

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determined until the replacement expert has been deposed;

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THEREFORE, the parties now hereby stipulate, through their counsel of record, as
follows:
1.

That the Final Pretrial Conference be continued for at least 60 days after

November 17, 2021, the date of the expert’s deposition previously scheduled; and
2.

That the time for filing the Joint Pretrial Statement be extended to 21 days prior to

the continued Final Pretrial Conference date.
STIPULATION AND ORDER
Case No. 2:15-CV-00967 KJM DB

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IT IS SO STIPULATED.

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DATE: October 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: October 5, 2021

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_/s/ Gary W. Gorski__
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:

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1.

The Final Pretrial Conference set for October 29, 2021 is vacated and rescheduled

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for February 11, 2022, which is at least 60 days after the date of the expert witness’ deposition;

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and

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2.

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January 21, 2022.

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That the parties’ time to file the Joint Pretrial Statement shall be continued to

IT IS SO ORDERED.
DATED: October 5, 2021.

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STIPULATION AND ORDER
Case No. 2:15-CV-00967 KJM DB

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