Beecham et al v. Roseville City School District et al

Filing 86

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 5/3/2017 ORDERING the date for the completion of expert discovery is CONTINUED to 6/15/2017. (Becknal, R)

1
2
3
4
5

PETER W. ALFERT, ESQ. (SBN 83139)
IAN HANSEN, ESQ. (SBN 255449)
LAW OFFICES OF PETER ALFERT, APC
200 Pringle Ave., Suite 450
Walnut Creek, California 94596
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

6

11

TODD BOLEY, (SBN 64119)
JUSTIN YOUNG, (SBN 267315)
LAW OFFICES OF TODD BOLEY
2381 Mariner Square Drive, Suite 280
Alameda, CA 94501
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

12

Attorneys for PLAINTIFFS

7
8
9
10

13

UNITED STATES DISTRICT COURT

14

EASTERN DISTRICT OF CALIFORNIA

15
16
17
18
19
20
21

DUANE BEECHAM, KIMBERLY BEECHAM,
S.Y.B., a minor by and through her co-guardians ad
litem DUANE BEECHAM and KIMBERLY
BEECHAM; OLIVER VERGARA, JENNIFER
VERGARA, E.V., a minor by and through his coguardians ad litem OLIVER VERGARA and
JENNIFER VERGARA; and M.B., a minor by and
through his guardian ad litem MANOJ
THOTTASSERI,

22
23
24
25
26

Case No.: 2:15-CV-01022-KJM-EFB
STIPULATION AND ORDER TO
EXTEND EXPERT DISCOVERY
CUTOFF
Judge: Hon. Kimberly J. Mueller

Complaint Filed: May 12, 2015

Plaintiffs,

Trial Date: November 27, 2017

v.
ROSEVILLE CITY SCHOOL DISTRICT,
THERESA VANWAGNER, GEORGE ROOKS,
JERROLD JORGENSEN and DOES 1-30,
Defendants.

27
28

1
STIPULATION AND ORDER
TO EXTEND EXPERT DISCOVERY CUTOFF

2:15-CV-01022-KJM-EFB

Plaintiffs DUANE BEECHAM, KIMBERLY BEECHAM, S.Y.B., a minor by and

1
2

through her co-guardians ad litem DUANE BEECHAM and KIMBERLY BEECHAM;

3

OLIVER VERGARA, JENNIFER VERGARA, E.V., a minor by and through his co-guardians

4

ad litem OLIVER VERGARA and JENNIFER VERGARA; M.B., a minor by and through his

5

guardian ad litem MANOJ THOTTASSERI, by and through their counsel Peter W. Alfert, of

6

Law Offices of Peter Alfert, APC, and Todd Boley and Justin Young of Law Offices of Todd

7

Boley; Defendants ROSEVILLE CITY SCHOOL DISTRICT, GEORGE ROOKS, and

8

JERROLD JORGENSEN, by and through their counsel, Carol Wieckowski of Evans,

9

Wieckowski, Ward & Scoffield; and Defendant THERESA VAN WAGNER, by and through her

10

counsel, Natasha Langenfeld of Longyear, O’Dea & Lavra, LLP, hereby submit the following

11

stipulation to extend the deadline to complete expert discovery to June 15, 2017.

12

RECITALS

13

WHEREAS, on November 24, 2015, this Court’s Pretrial Scheduling Order (Doc. 27) set

14

May 1, 2017, as the date by which expert discovery must be completed; and

15

WHEREAS, the parties have worked diligently to attempt to schedule the deposition of

16

all experts’ consultants before the Court’s deadline, but have been unable to do so; and

17

WHEREAS, the deposition of Plaintiffs’ consultants Peter Formuzis and Joseph

18

Schwartberg are scheduled for May 3, 2017 and May 16, 2017 respectively and the deposition

19

of Defendants’ consultant Anlee Kuo is scheduled for May 22, 2017 and it is agreed among the

20

parties that the deposition of Miriam King will be set for a date on or before June 15, 2017.

21
22

IT IS HEREBY STIUPLATED, by and between Plaintiffs and Defendants, by and
through their respective counsel that:

23
24

1.

The parties respectfully request that the Court continue the deadline by which the

parties are to complete expert discovery to June 15, 2017.

25
26

///

27

///

28

///
2
STIPULATION AND ORDER
TO EXTEND EXPERT DISCOVERY CUTOFF

2:15-CV-01022-KJM-EFB

1

Dated: April 25, 2017

LAW OFFICES OF PETER ALFERT, APC

2

/s/ Peter Alfert
PETER ALFERT
Attorneys for Plaintiffs

3
4
5

Dated: April 25, 2017

LAW OFFICES OF TODD BOLEY

6

/s/ Todd Boley
TODD BOLEY
Attorneys for Plaintiffs

7
8
9
10

Dated: April 25, 2017

LONGYEAR, O’DEA & LAVRA, LLP

11

/s/ Gregory O’Dea
GREGORY P. O’DEA
NATASHA LAGENFELD
Attorneys for Defendant
Theresa Van Wagner

12
13
14
15
16

Dated: April 25, 2017

EVANS, WIECKOWSKI, WARD
& SCOFFIELD, LLP

17
18

/s/ Carol Wieckowski
CAROL A. WIECKOWSKI
Attorneys for Defendants
Roseville City School District, George Rooks,
and Jerrold Jorgensen

19
20
21
22
23
24
25
26
27
28

3
STIPULATION AND ORDER
TO EXTEND EXPERT DISCOVERY CUTOFF

2:15-CV-01022-KJM-EFB

ORDER

1
2
3

Having read and considered the parties’ Stipulation to Extend The Expert Discovery

4

Cutoff, IT IS HEREBY ORDERED THAT:

5

1. The date for the completion of expert discovery shall be continued to June 15, 2017.

6
7

IT IS HEREBY ORDERED.
DATED: May 3, 2017.

8
9

UNITED STATES DISTRICT JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

4
STIPULATION AND ORDER
TO EXTEND EXPERT DISCOVERY CUTOFF

2:15-CV-01022-KJM-EFB