Gasca v. County of Sacramento

Filing 16

STIPULATION and ORDER modifying the scheduling order, signed by Magistrate Judge Carolyn K. Delaney on 3/31/16. Expert Disclosure due 6/27/2016 and Rebuttal Expert Disclosure due 7/25/2016. All other dates shall remain the same. (Kastilahn, A)

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LONGYEAR, O’DEA & LAVRA, LLP
John A. Lavra, CSB No.: 114533
Kelley S. Kern, CSB No.: 221265
3620 American River Drive, Suite 230
Sacramento, CA 95864
Phone: [phone]
Facsimile: 916-974-8510

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Attorneys for Defendant COUNTY OF SACRAMENTO

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LAW OFFICE OF BROWN & GESSELL
Douglas A. Gessell, SBN: 210112
Steven L. Brown, SBN: 166278
2155 W. March Lane, Suite 1D
Stockton, CA 95207
Phone: [phone]
Facsimile: 209-466-5480

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Attorneys for Plaintiff MARTIN GASCA

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

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MARTIN GASCA, an individual

) Case No.: 2:15-cv-01109-WBS-CKD
)
Plaintiff,
) STIPULATION TO MODIFY
) SCHEDULING ORDER
vs.
)
)
COUNTY OF SACRAMENTO, a municipal )
corporation; DOE OFFICER 1 and DOES 2- )
25,
)
)
Defendants.
)
The Plaintiff Martin Gasca, by and through his attorneys, and Defendants, County of

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Sacramento and Deputy Nathan Burnette, by and through their attorneys, stipulate as follows:

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The current Scheduling Order has established May 13, 2016 as the last day to disclose

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experts and their reports pursuant to FRCP 26(a)(2). Rebuttal experts are to be disclosed by June

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10, 2016.

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The parties are actively engaged in discovery. They have exchanged written discovery

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requests and responses, as well as produced documents. Defendant took the deposition of the

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Plaintiff on March 15, 2016. The parties have not yet received the transcript. Plaintiff has

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noticed the depositions of Defendant Burnette and two third party County witnesses for March

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31, 2016. Defendant would also like to take the depositions of two third party witnesses on a

STIPULATION TO MODIFY SCHEDULING ORDER Page - 1

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mutually agreeable date. Some travel may be required for one of these additional depositions

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due to the witness’s residence.

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In light of the foregoing, the parties believe they will be unable to complete discovery on

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the claims and defenses with sufficient remaining time for comprehensive review by an expert

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before the current May 13, 2016 deadline. Thus, the Parties have stipulated to extend the time

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for expert disclosures by forty-five (45) days.

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The parties stipulate to modify the scheduling order as follows:

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1. Expert Disclosure – June 27, 2016

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2. Rebuttal Expert Disclosure- July 25, 2016

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All other dates shall remain the same.

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IT IS SO STIPULATED

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Dated: March 29, 2016

LONGYEAR, O’DEA & LAVRA, LLP

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By: /s/ Kelley S. Kern
JOHN A. LAVRA
KELLEY S. KERN
Attorneys for Defendant

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Dated: March 29, 2016

LAW OFFICE OF BROWN & GESSELL
By: /s/ Douglas A. Gessell
DOUGLAS A. GESSELL
STEVEN L. BROWN
Attorneys for Plaintiff

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STIPULATION TO MODIFY SCHEDULING ORDER Page - 2

ORDER

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Pursuant to stipulation, it is ordered that the parties exchange Expert Witness Reports by June

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27, 2016 and Rebuttal Expert Witness Reports by July 25, 2016.

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IT IS SO ORDERED:

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Dated:

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March 31, 2016

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO MODIFY SCHEDULING ORDER Page - 3