Jackson v. Calone, et al.

Filing 167

STIPULATION and ORDER 166 signed by District Judge Troy L. Nunley on 8/6/2018 ORDERING the deadline to Disclose Experts is EXTENDED to 9/10/2018. (Krueger, M)

1 Mark E. Ellis - 127159
Theresa M. LaVoie - 143773
2 ELLIS LAW GROUP LLP
1425 River Park Drive, Suite 400
3 Sacramento, CA 95815
Tel: [phone]
4 Fax: [phone]
[e-mail]
5 [e-mail]
6 Attorneys for Defendants RICHARD CALONE; CALONE & HARREL LAW GROUP, LLP;
CALONE & BEATTIE, LLP; CALONE LAW GROUP, LLP
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11 DOROTHY RODDEN JACKSON,

Case No.: 2:16-cv-00891 TLN KJN

12

STIPULATION AND ORDER TO MODIFY
THE SCHEDULING ORDER TO EXTEND
THE DEADLINE TO DISCLOSE EXPERTS

Plaintiff,

13 v.
14 RICHARD CALONE; CALONE & HARREL
LAW GROUP, LLP; CALONE & BEATTIE,
15 LLP; CALONE LAW GROUP, LLP,
16

(Fed. R. Civ. P. 26)

Defendants.

17
18

Plaintiff Dorothy Jackson and Defendants Richard Calone, Calone & Harrel Law Group, LLP,

19 Calone & Beattie, LLP, and Calone Law Group, LLP hereby agreed and request this Court to extend
20 the deadline to disclose experts pursuant to Federal Rules of Civil Procedure 26, by thirty days.
21 Currently, expert disclosure is scheduled for August 9, 2018, and the parties seek an extension of time
22 to September 10, 2018.
23

The parties require additional time to designate and prepare their experts based on several

24 factors. First, discovery in this case was delayed after Plaintiff notified Defendants that she was unable
25 to attend her deposition due to medical issues. This resulted in Defendants bringing a motion for
26 terminating sanctions, motions to compel, and the deposition of Plaintiff’s medical expert. Plaintiff
27 eventually sought and obtained a protective order that her deposition not be taken.
28
-1_____________________________________________________________________________________________________________________________ _________________________________________________________________________________________

STIPULATION AND ORDER TO MODIFY THE SCHEDULING ORDER TO EXTEND THE DEADLINE TO DISCLOSE
EXPERTS

1
Second, Plaintiff filed a motion to amend the Complaint which has not yet been ruled on.
2

Depending on the outcome of this motion, additional issues may need to be addressed by the parties’

3
experts.
4
Consequently, the parties have agreed and request this Court to move the expert disclosure
5
deadline from August 9, 2018 to September 10, 2018. All other provisions of the scheduling order
6
would remain the same.
7
So Stipulated:
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Dated: July 17, 2018
9
NAGELY, KIRBY & WINBERRY, LLP
10
11
By /s/ James R. Kirby II________________________
James R. Kirby II
Attorney for Plaintiff
DOROTHY RODDEN JACKSON

12
13
14 Dated: August 6, 2018

ELLIS LAW GROUP LLP

15
16

By /s/ Theresa M. LaVoie_______________________
Theresa M. LaVoie
Attorney for Defendants DEFENDANTS RICHARD
CALONE; CALONE & HARREL LAW GROUP, LLP;
CALONE & BEATTIE, LLP; CALONE LAW GROUP,
LLP

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18
19
20

Based on the stipulation of the parties and for good caue shown, the Court orders that the

21

22 dealine to disclose experts shall be extended by thirty days from August 9, 2018 to September 10,
23 2018.
24

SO ORDERED

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Dated: August 6, 2018
26
27
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Troy L. Nunley
United States District Judge
-2_____________________________________________________________________________________________________________________________ _________________________________________________________________________________________

STIPULATION AND ORDER TO MODIFY THE SCHEDULING ORDER TO EXTEND THE DEADLINE TO DISCLOSE
EXPERTS