Blight v. Manteca et al

Filing 12

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 9/13/2016 ORDERING that the deadline for expert disclosure is EXTENDED to 11/8/2016. The deadline for rebuttal expert disclosure is EXTENDED to 11/29/2016. The deadline for all discovery remains unchanged; it closes on 1/10/2017. (Zignago, K.)

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Attorneys for Defendants
CITY OF MANTECA, ARMANDO GARCIA, RANCH
JOHNSON, KIRK DOTY, MIKE KEENER, IAN
OSBORN, ARMEN AVAKIAN, PAUL CARMONA and
CHRIS S. MRAZ

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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DALE L. ALLEN, JR., State Bar No. 145279
[e-mail]
KEVIN P. ALLEN, State Bar No. 252290
[e-mail]
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
180 Montgomery Street, Suite 1200
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]

UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO COURTHOUSE

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JOANNE BLIGHT,
Plaintiff,

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Case No.: 2:15-cv-02513-WBS-CKD
STIPULATION TO EXTEND EXPERT
DISCOVERY DEADLINE; ORDER

v.
CITY OF MANTECA, a Municipal
Corporation, Manteca Police Department
Detectives ARMANDO GARCIA,
Individually, RANCH JOHNSON,
Individually, KIRK DOTY, Individually,
MIKE KEENER, Individually, IAN
OSBORN, Individually, and ARMEN
AVAKIAN, Individually, Manteca Police
Department Sergeants PAUL CARMONA
and CHRIS S. MRAZ, in their Individual
and Supervisory capacities, and DOES 1
THROUGH 60, Jointly and Severally,
Defendants.

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122806.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-CKD

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TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS

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OF RECORD:

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In its Scheduling Order dated March 22, 2016 (Docket No. 8), the Court set various

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deadlines, including: expert disclosure (September 13, 2016); rebuttal expert disclosure (October

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4, 2016); and discovery cutoff (January 10, 2017).

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Plaintiff JOANNE BLIGHT and Defendants CITY OF MANTECA, ARMANDO

AVAKIAN, PAUL CARMONA and CHRIS S. MRAZ (“Defendants”) have met-and-conferred

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on these dates and -- despite due diligence by all sides -- believe additional time will be needed

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for expert and rebuttal disclosures. Discovery is still being conducted that will bear upon expert

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opinions and reports. Depositions of all Defendants were noticed at the outset of discovery, but

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due to a pending discovery issue that will require resolution by the Court via a motion – as well as

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the parties’ desire to accommodate the schedules of the police officer defendants to the extent

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possible and other circumstances outside the control of the parties – these depositions had to be

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postponed. The depositions that can proceed have been going forward, however. An additional

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challenge has been reconciling the numerous schedules of attorneys on both sides of this case,

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including their busy trial calendars. Nonetheless, the parties have diligently met-and-conferred to

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move the discovery process forward and have been conducting the necessary depositions and

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other discovery, with more on calendar. Based on the foregoing circumstances, the parties

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

GARCIA, RANCH JOHNSON, KIRK DOTY, MIKE KEENER, IAN OSBORN, ARMEN

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ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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respectfully stipulate to the following, and request the Court’s approval.

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By and through the counsel of record for Defendants and Plaintiff, the parties stipulate as
follows:

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1.

The deadline for expert disclosure is extended to November 8, 2016;

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2.

The deadline for rebuttal expert disclosure is extended to November 29, 2016;

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3.

The deadline for all discovery remains unchanged; it closes on January 10, 2017.

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122806.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-CKD

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Respectfully submitted,

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Dated: September 9, 2016

LAW OFFICES OF SANJAY S. SCHMIDT

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By:

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/s/ Sanjay S. Schmidt
SANJAY S. SCHMIDT
Attorneys for Plaintiff
JOANNE BLIGHT

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Dated: September 9, 2016

ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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By:

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/s/ Kevin P. Allen
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
CITY OF MANTECA, ARMANDO
GARCIA, RANCH JOHNSON, KIRK DOTY,
MIKE KEENER, IAN OSBORN, ARMEN
AVAKIAN, PAUL CARMONA and CHRIS
S. MRAZ

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: September 13, 2016

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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122806.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-CKD