Ramos v. Williams Unified School District

Filing 25

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/2/18 ORDERING that Expert Disclosure due by 5/4/2018; Supplemental Expert Disclosure due by 5/18/18; Discovery Cut-off by 7/6/2018. Dispositive Motion Filing by 7/10/2018; Dispositiv e Motion hearing 8/7/18 @1:30 p.m. Joint Pretrial Statement due by 9/21/18; Pretrial Conference SET for 9/28/2018 at 10:00 AM. Jury Trial SET for 11/5/2018 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Mena-Sanchez, L)

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James K. Ward, Esq. (SBN 117639)
Eric Garner, Esq. (SBN 131232)
EVANS, WIECKOWSKI & WARD, LLP
745 University Avenue
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
Williams Unified School District, Public Entity and Judith Rossi

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA

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ARMANDO RAMOS,
Plaintiff,

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vs.

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WILLIAMS UNIFED SCHOOL DISTRICT
and DOES 1 through 50,

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Defendants.

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Case No. 2:16-CV-01941

STIPULATION TO MODIFY PRE-TRIAL
SCHEDULING ORDER (DOCUMENT 8)
AS MODIFIED BY COURT ORDER
(DOCUMENT 21) RE (1) EXPERT
DISCLOSURE DEADLINE; (2)
DISCOVERY CUT-OFF; (3)
DISPOSITIVE MOTIONS; AND (4)
TRIAL DATE; DECLARATIONS IN
SUPPORT THEREOF; ORDER

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IT IS HEREBY STIPULATED by Plaintiff, ARMANDO RAMOS, by and through his
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attorneys, and Defendants WILLIAMS UNIFIED SCHOOL DISTRICT and JUDITH ROSSI, by

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and through their attorneys, stipulate that the deadlines and trial date set forth in the Court’s Pre-

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Trial Scheduling Oder (Document 8) as modified by the Court’s December 19, 2017, Order

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(Document 21) be continued to:
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1.

Expert Disclosure:

5/4/18;

2. Supplemental Expert Disclosure:

5/18/18;

STIPULATION AND ORDER - 1

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3.

Discovery Cut-off:

7/6/18;

4. Dispositive Motion Filing:

7/10/18;

5. Dispositive Motion Hearing:

8/7/18 @ 1:30 p.m.

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6. Joint Pretrial Statement:

9/21/18;

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7. Pretrial Conference:

9/28/18 @ 10 a.m.; and

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8. Jury Trial:

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11/5/18 @ 9 a.m.

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The parties submit that good cause exists to modify the court’s Pre-Trial Scheduling
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Order, as modified, as set forth above.
IT IS SO STIPULATED.
Dated: February 2, 2018

EVANS, WIECKOWSKI & WARD, LLP

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/s/ James K. Ward
___________________________________
JAMES K. WARD
ERIC GARNER
Attorneys for Defendants WILLIAMS
UNIFIED SCHOOL DISTRICT

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Dated: February 2, 2018

LAW OFFICES OF JILL TELFER

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/s/ Jill Telfer
___________________________________
JILL TELFER
Attorney for Plaintiff ARMANDO RAMOS

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STIPULATION AND ORDER - 2

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DECLARATION OF ERIC GARNER
I, Eric Garner, do hereby declare and say the following:

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1.

I am one of the attorneys of record for the Defendants in the above-entitled action.

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I have prepared this Declaration as evidence in support of the parties’ stipulation and request to

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this Court to modify the Pre-Trial Scheduling order in this case. Good cause exists to do so.

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I declare under penalty of perjury under the laws of the United States of America that the

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facts stated above in the stipulation of the parties is true and correct. This Declaration was
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executed on February 2, 2018 in Sacramento, California.
/s/ Eric Garner
_____________________________

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DECLARATION OF JILL TELFER

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I, Jill Telfer, do hereby declare and say the following:

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1.

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I am the attorney of record for Plaintiff in the above-entitled action. I have

prepared this Declaration as evidence in support of the parties’ stipulation and request to this

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Court to modify the Pre-Trial Scheduling order in this case. Good cause exists to do so.
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I declare under penalty of perjury under the laws of the United States of America that the

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facts stated above in the stipulation of the parties is true and correct. This Declaration was

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executed on February 2, 2018 in Sacramento, California.

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/s/ Jill Telfer
_____________________________

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STIPULATION AND ORDER - 3

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ORDER
Based upon the stipulation of the parties and good cause appearing, the Court orders that

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the Pre-Trial Scheduling Order is hereby modified as follows:
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1.

Expert Disclosure:

5/4/18;

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2. Supplemental Expert Disclosure:

5/18/18;

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3. Discovery Cut-off:

7/6/18

4. Dispositive Motion Filing:

7/10/18;

5. Dispositive Motion Hearing:

8/7/18 @ 1:30 p.m.

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6. Joint Pretrial Statement:

9/21/18;

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7. Pretrial Conference:

9/28/18 @ 10 a.m.; and

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8. Jury Trial:

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11/5/18 @ 9 a.m.

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IT IS SO ORDERED.
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Dated: 2/2/2018

/s/ John A. Mendez_________________
UNITED STATES DISTRICT COURT
JUDGE

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STIPULATION AND ORDER - 4