Hill v. Fairfield Police Department et al

Filing 33

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 2/7/17: Expert discovery cutoff now set for February 13, 2017, shall be continued to May 14, 2017.(Kaminski, H)

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PAUL ALAGA, CASBN 221165
IAN KELLEY CASBN 215393
LEWIS ROMERO, CASBN 197231
885 Bryant Street, Suite 202
San Francisco, California 94103
415-581-0885 Tel.
415-581-0887 Fax.
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JEROME HILL

Case No. 15-cv-01820 HSG
Plaintiff,

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vs.

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STIPULATION TO EXTEND TIME FOR
EXPERT DISCOVERY

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FAIRFIELD POLICE DEPARTMENT; CITY
OF FAIRFIELD, a municipal corporation;
REBECCA BELK, individually and in her
official capacity as a Police Officer for the CITY
OF FAIRFIELD; MICHAEL AMBROSE,
individually and in his official capacity as a
Police Officer for the CITY OF FAIRFIELD;
and DOES 1-50,
Defendants.
/

ORDER

Date Action filed: May 28, 2015
Trial Date:
Not Set

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Plaintiff JEROME HILL and Defendants FAIRFIELD POLICE DEPARTMENT, CITY OF

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FAIRFIELD, REBECCA BELK, and MICHAEL AMBROSE by and through counsel, hereby

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stipulate and represent to the court the following.

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1)

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fact discovery for December 12, 2016 and the cutoff for expert discovery on February 13, 2017.

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2)

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cutoff for fact discovery to March 13, 2016.

That on March 7, 2016 this Court issued a scheduling order setting, inter alia, the cutoff for

On January 11, 2017, this Court, upon the request and stipulation of the parties, extended the

Stipulation to Extend Time for Expert Discovery and Order
Hill v. City of Fairfield et al. Case No. 15-cv-01820 HSG

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3)

The parties have made significant progress in their base discovery, including the depositions

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of the parties and percipient witnesses.

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4)

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Defendant request for a Rule 35 psychiatric and psychological exam of plaintiff. Although the

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parties have met and conferred in good faith, they have not been able to reach accord as to certain

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terms of the proposed exam.

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5)

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necessary expert discovery within the deadline set. A 90-day extension of time will allow the parties

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adequate time to conduct full and complete discovery in this case.

The plaintiff and defendant, through counsel, have extensively met and conferred regarding a

The volume of the expert discovery required has limited the parties’ ability to complete all the

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6)

Extending the deadline for expert discovery will not impact any other dates previously set by

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this Court; no trial date has been set.

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7)

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2017, be continued to May 14, 2017.

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IT IS SO STIPULATED.

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Dated: January 30, 2017

Therefore, the parties jointly request that the expert discovery cutoff now set for February 13,

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BERTRAND, FOX, et al.

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By:

/s/ Paul Alaga
Ian Kelley
Paul Alaga
Attorneys for Plaintiff
JEROME HILL

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By:

/s/ Gregory M. Fox
Gregory M. Fox
Parry A. Black
Attorneys for Defendants
CITY OF FAIRFIELD, FAIRFIELD
POLICE DEPARTMENT, REBECCA
BELK, and MICHAEL AMBROSE

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IT IS SO ORDERED.
Dated: February 7, 2017

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Stipulation to Extend Time for Expert Discovery and Order
Hill v. City of Fairfield et al. Case No. 15-cv-01820 HSG