Ramos v. Williams Unified School District

Filing 28

STIPULATION and ORDER signed by Magistrate Judge Edmund F. Brennan on 3/14/2018 APPROVING 27 Stipulation for Independent Mental Examination. (York, M)

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

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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) Case No. 2:16-cv-01941-JAM-EFB
)
) STIPULATION OF THE PARTIES
Plaintiff,
) REGARDING INDEPENDENT MENTAL
) EXAMINATION; ORDER
vs.
)
WILLIAMS UNIFIED SCHOOL DISTRICT; )
)
Judith Ross, as an individual, and DOES 1
)
through 20,
)
)
Defendant.
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)
It is hereby stipulated and agreed by and between Plaintiff, Armando Ramos by and
ARMANDO RAMOS,

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through his attorney of record and Defendant, Williams Unified School District and Judith Rossi,

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through their attorneys of record that Armando Ramos will submit to an independent mental

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examination to be performed as follows:

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(1) Dr. Ronald H. Roberts, Ph.D., ABPD on March 30, 2018, starting at 10:00 a.m. at

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M.O.A. Deposition Reporters, 855 Harter Parkway, Ste. 210, Yuba City, CA 95993;
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The examination to be performed by Dr. Roberts will consist of psychological testing. It

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is anticipated the duration of the psychological testing will take approximately four (4) hours,

STIPULATION OF THE PARTIES REGARDING INDEPENDENT MENTAL EXAMINATION - 1

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excluding appropriate breaks. Additional time will be allowed, as needed, only to facilitate any
needed rest breaks; and
(2) Dr. Charles Saldanha, MD, on April 13, 2018 at 10:00 a.m., at M.O.A. Deposition
Reporters, 855 Harter Parkway, Ste. 210, Yuba City, CA 95993, will conduct a detailed

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psychiatric interview lasting approximately five (5) hours. Additional time will be allowed, as
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needed, only to facilitate any needed rest break.

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Dr. Roberts’ and Dr. Saldanha’s resumes are attached hereto.

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No attorneys or other third parties shall be present during the testing and interview with

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Armando Ramos.

The psychiatric interview will be recorded by audio and copies of the

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interview made available to both parties.

Plaintiff Armando Ramos may also record the

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examination. It is agreed the interview is not for purposes of collecting factual information to

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defend liability in this case and that it is exclusively to evaluate Plaintiff Armando Ramos’

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emotional and psychiatric state, third party rights of privacy will be maintained.

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The total time spent testing and interviewing Armando Ramos will likely be no more than
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10-12 hours.
Plaintiff will obtain, via authorizations signed by Armando Ramos, the following
categories of documents:
1.
VA records; and

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2.

The documents responsive to the Subpoena served on Greene and Roberts.

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Upon production of the above-referenced documents Plaintiff will produce all of them

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except those that Plaintiff contends are privileged. As to privileged documents, Plaintiff agrees
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to prepare and serve a privilege log by March 23, 2018. The parties will then meet and confer

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about the documents over which there is disagreement. Absent resolution, the parties agree to

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submit the issue to the court.

STIPULATION OF THE PARTIES REGARDING INDEPENDENT MENTAL EXAMINATION - 2

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IT IS SO STIPULATED.
Dated: March 14, 2018

LAW OFFICES OF JILL P. TELFER

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/s/ Jill P. Telfer
________________________________
JILL P. TELFER
Attorney for Plaintiff
ARMANDO RAMOS

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Dated: March 14, 2018

EVANS, WIECKOWSKI, WARD &
SCOFFIELD, LLP

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/s/ James K. Ward
_____________________________
JAMES K. WARD
ERIC R. GARNER
Attorneys for Defendant
WILLIAMS UNIFIED SCHOOL
DISTRICT

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IT IS SO ORDERED.

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DATED: March 14, 2018.
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STIPULATION OF THE PARTIES REGARDING INDEPENDENT MENTAL EXAMINATION - 3