Ainely, et al. v. City of South Lake Tahoe, et al.

Filing 41

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 4/16/18: Discovery due by 6/29/2018 and Designation of Expert Witnesses due by 8/3/2018. (Kaminski, H)

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MICHAEL J. HADDAD (State Bar No. 189114)
JULIA SHERWIN (State Bar No. 189268)
MAYA SORENSEN (State Bar No. 250722)
TERESA ALLEN (State Bar No. 264865)
HADDAD & SHERWIN LLP
505 Seventeenth Street
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Patrick Jackson
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LAW OFFICES OF DALE K. GALIPO
DALE K. GALIPO (State Bar No. 144074)
TANYA SUKHIJA (State Bar No. 295589)
21800 Burbank Boulevard, Suite 310
Woodland Hills, California 91367
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff Angela Ainley

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ANGELA AINLEY, individually and as
successor-in-interest for KRIS JACKSON ,
Deceased; PATRICK JACKSON, individually
and as successor-in-interest for KRIS
JACKSON, Deceased;
Plaintiffs,
vs.

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)
)
)
)
)
)
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CITY OF SOUTH LAKE TAHOE, a public
)
entity; JOSHUA KLINGE, individually and as a )
police officer for the City of South Lake Tahoe; )
ELI CLARK, individually and as a police
)
officer for the City of South Lake Tahoe; City
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of South Lake Tahoe Chief of Police BRIAN
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UHLER, individually; and DOES 2 THROUGH )
10, Jointly and Severally,
)

No: 2:16-cv-00049-TLN-CKD

STIPULATION AND ORDER TO
MODIFY CASE MANAGEMENT
DATES

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Defendants

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No: 2:16-cv-00049-TLN-CKD: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT DATES

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The parties respectfully request that the Court modify the case management and trial dates
as follows:
Case Event

Current Date

Proposed Date

1. Non-expert discovery

April 30, 2018

June 29, 2018

2. Expert reports

June 28, 2018

August 3, 2018

Good Cause to Continue Pretrial Dates:
Plaintiffs have deposed the two defendant officers in this matter with Officer Klinge now
residing in Oregon. Plaintiffs must still depose the following people: Defendant Chief of Police
Brian Uhler, South Lake Tahoe Police Department (SLTPD) Homicide Investigator J. Roberson,
SLTPD Sgt. Cheney, El Dorado Sheriff Office Deputy Aguilar, and Tiana Perez, the witness to
Kris Jackson’s shooting. Defendants still need to depose the two Plaintiffs in addition to at least
two additional eyewitnesses (both of whom were transient at the time and have not been readily
available). Due to all counsel’s conflicting court dates and depositions in other cases, as well as
previously scheduled vacations for counsel, the parties must depose the above-mentioned
deponents after the current close of fact discovery. The parties have agreed on dates by which to
depose all the remaining deponents. All other case management dates would remain the same.
The following represents each party’s counsel’s case and vacation schedule from May 2017
to the present:
Counsel for Defendants’ trial schedule May 2017 through 2018:

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Peralez v. City of Fresno
May 2017
Hernandez v. City of Salinas July 2017
Gonzalez v. City of Lindsay July 2017
Knox v. City of Fresno
Jan - Oct 2017
Ma v. City of Fresno
Oct 2017
Rodriguez v. City of Fresno Nov 2017
Garcia v. City of Fresno
Sept 18, 2018
Garcia v. City of Santa Maria Nov 5, 2018
Gonzalez v. City of Fresno Dec 4, 2018
Casillas v. City of Fresno
Feb 26, 2019
Jackson v. City of South Lake Tahoe Mar 2019

Dismissed just prior to trial
Settled shortly before trial
Dismissed shortly before trial
Trial & Appeal
Dismissed day prior to trial
Trial

Counsel for Plaintiff Ainley’s trial schedule May 2017 to present:

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No: 2:16-cv-00049-TLN-CKD: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT DATES

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See Attachment A.

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Counsel for Plaintiff Jackson’s trial, deposition, and vacation schedule May 2017 to present:

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May v. San Mateo County
Perkins v. Oakland
Neuroth v. Mendocino County
Bascos v. Santa Clara County
Slusher v. Napa
Neuroth v. Mendocino County
Martinez v. Pittsburg
Slusher v. Napa

June, 2017
Sept, 2017
Oct, 2017
Nov-Dec, 2017
Jan-Feb, 2018
March, 2018
April-May, 2018
October, 2018

Trial
Deps of Plaintiffs and Defendants
Deps of witnesses
Deps of Defendants
Deps of Defendants
Deps of Expert witnesses
Deps of Defendants and witnesses
Trial

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Counsel for Plaintiff Jackson has also had to respond to a number of motions to dismiss and

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motions for summary judgment, in the above cases and in other cases. In addition to the workload

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in other cases, Ms. Sherwin and Mr. Haddad have scheduled vacation April 7-13, 2018 and May

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19-31, 2018 after having to cancel previous vacations.

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For the forgoing reasons, the parties respectfully request that the Court modify the case
management order as requested herein.

15 Dated: April 11, 2018

HADDAD & SHERWIN LLP
By:/s/ Maya Sorensen

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MAYA SORENSEN
Attorneys for Plaintiff Jackson

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DATED: April 11, 2018

LAW OFFICES OF DALE K. GALIPO

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_/s/ Dale Galipo________
Dale K. Galipo
Attorneys for Plaintiff Angela Ainley

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DATED: April 11, 2018

FERGUSON PRAET & SHERMAN

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__/s/ Bruce Praet___________
Bruce Praet
Attorneys for Defendants City of South Lake
Tahoe and Joshua Klinge

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No: 2:16-cv-00049-TLN-CKD: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT DATES

MODIFIED CASE MANAGEMENT ORDER

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Pursuant to the Court’s Minute Order and stipulation of the parties, and for good cause, IT
IS SO ORDERED.

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Dated: April 16, 2018
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Troy L. Nunley
United States District Judge

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No: 2:16-cv-00049-TLN-CKD: STIPULATION AND ORDER TO MODIFY CASE MANAGEMENT DATES