Blight v. Manteca et al

Filing 28

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 11/08/2016 ORDERING that the deadline for expert disclosure is EXTENDED to 11/22/2016. The deadline for rebuttal expert disclosure is EXTENDED to 12/13/2016. The deadline for all discovery will remain 01/10/2017. (Butolph, J)

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1 2 3 4 5 6 7 Attorneys for Defendants CITY OF MANTECA, ARMANDO GARCIA, RANCH JOHNSON, KIRK DOTY, MIKE KEENER, IAN OSBORN, ARMEN AVAKIAN, PAUL CARMONA and CHRIS S. MRAZ 9 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 DALE L. ALLEN, JR., State Bar No. 145279 dallen@aghwlaw.com KEVIN P. ALLEN, State Bar No. 252290 kallen@aghwlaw.com ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 180 Montgomery Street, Suite 1200 San Francisco, CA 94104 Telephone: (415) 697-2000 Facsimile: (415) 813-2045 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 SACRAMENTO COURTHOUSE 13 Plaintiff, 14 15 16 17 18 19 20 21 22 Case No.: 2:15-cv-02513-WBS-CKD JOANNE BLIGHT, v. STIPULATION TO EXTEND EXPERT DISCOVERY DEADLINE; [PROPOSED] ORDER 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. 23 24 25 26 27 28 1 133561.1 STIPULATION; PROPOSED ORDER 2:15-CV-02513-WBS-CKD 1 TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS 2 OF RECORD: 3 4 5 In its Scheduling Order dated March 22, 2016 (Docket No. 8), the Court set various deadlines, including: expert disclosure (September 13, 2016); rebuttal expert disclosure (October 4, 2016); and discovery cutoff (January 10, 2017). 6 7 9 disclosure to November 8, 2016 and rebuttal disclosure to November 29, 2016. (Docket No. 11). The basis for the stipulation was outstanding depositions. (Id.) The Court granted the request. (Docket No. 12). 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 On September 9, 2016, the parties submitted a stipulated request to extend expert 11 12 13 On October 14, 2016, the parties filed their Joint Statement on Discovery Dispute (re: confidential informant). (Docket No. 20). The hearing occurred on November 2nd; the Court issued an order on November 7th. As the parties evaluate the order and determine the next steps in the case, they respectfully request additional time for expert and rebuttal disclosures.1 14 15 Based on the foregoing circumstances, the parties respectfully stipulate to the following, and request the Court’s approval. 16 17 By and through the counsel of record for Defendants and Plaintiff, the parties stipulate and request the following: 18 1. 21 22 23 24 25 That the deadline for rebuttal expert disclosure be extended to December 13, 2016; 3. 20 That the deadline for expert disclosure be extended to November 22, 2016; 2. 19 That, for the time being, the deadline for all discovery remain January 10, 2017. /// /// /// /// /// 26 27 28 1 The parties may also request an extension of the discovery deadline. If so, they will file such request in the coming weeks. 2 133561.1 STIPULATION; PROPOSED ORDER 2:15-CV-02513-WBS-CKD 1 Respectfully submitted, 2 3 Dated: November 8, 2016 LAW OFFICES OF SANJAY S. SCHMIDT 4 5 By: 6 7 /s/ Sanjay S. Schmidt SANJAY S. SCHMIDT Attorneys for Plaintiff JOANNE BLIGHT 9 Dated: November 8, 2016 10 180 Montgomery Street, Suite 1200 San Francisco, California 94104 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP 8 11 ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP By: 12 13 14 15 /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 16 17 PURSUANT TO STIPULATION, IT IS SO ORDERED. 18 19 DATED: November 8, 2016 20 21 22 23 24 25 26 27 28 3 133561.1 STIPULATION; PROPOSED ORDER 2:15-CV-02513-WBS-CKD

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