Munshower v. United States of America

Filing 15

AMENDED STIPULATION and ORDER TO EXTEND PRETRIAL SCHEDULE DEADLINES signed by District Judge John A. Mendez on 7/18/17. The dates set forth in the 12/14/16 Status (Pretrial Scheduling) Order, 11 are EXTENDED as follows: Expert Disclosure 10/31/20 17. Rebuttal Expert Disclosure 11/30/2017. Discovery cutoff: 1/31/2018. Dispositive Motion filing 3/13/2018. Dispositive Hearing set for 4/10/2018 at 01:30 PM. Joint Pretrial Statement due: 5/18/2018. Final Pretrial Conference set for 5/25/2018 at 10:00 AM. Trial SET for 7/9/2018 at 09:00 AM.(Mena-Sanchez, L)

1 PHILLIP A. TALBERT
United States Attorney
2 BOBBIE J. MONTOYA
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, California 95814
4 Telephone: [phone]
5 Attorneys for Defendant United States of America
6 NICHOLAS J. MASTRANGELO, ESQ. (Cal. Bar No. 160495)
MASTRANGELO LAW OFFICES
7 A Professional Corporation
Two Theatre Square, Suite 234
8 Orinda, CA 94553
Telephone: [phone]
9 Telefax: [phone]
10 Attorneys for Plaintiff Judy Munshower
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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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JUDY MUNSHOWER,
Plaintiff,

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Case No. 2:16-CV-02386-JAM-EFB
AMENDED STIPULATION AND ORDER TO
EXTEND PRETRIAL SCHEDULE DEADLINES

v.
UNITED STATES OF AMERICA,
Defendant.

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IT IS HEREBY STIPULATED by and between the parties, through their respective undersigned

22 attorneys, and upon the Court’s approval, that the dates set forth in the December 14, 2016 Status
23 (Pretrial Scheduling) Order, ECF 11, be extended as follows:
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Expert disclosure:

October 31, 2017 (from July 31, 2017)

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Rebuttal expert disclosure:

November 30, 2017 (from August 31, 2017)

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Discovery cutoff:

January 31, 2018 (from October 31, 2017)

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Dispositive motion filing:

March 13, 2018 (from January 16, 2018)

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Dispositive hearing:

April 10, 2018 at 1:30 p.m. (from February 13, 2018)

Amended Stipulation and [Proposed] Order to Extend
Pretrial Schedule Deadlines

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Joint pretrial statement due: May 18, 2018 (from March 23, 2018)

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Final pretrial conference:

May 25, 2018 at 10:00 a.m. (from March 30, 2018)

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Trial:

July 9, 2018 at 9:00 a.m. (from May 7, 2018)

4 In all other respects, the December 14, 2016 Status (Pretrial Scheduling) Order shall remain in effect.
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Modification of the pretrial schedule is a necessity because one of defendant’s retained experts

6 encountered a medical emergency that at present is uncertain whether he will need emergency surgery in
7 the upcoming days that will prevent him from being able to perform an independent medical
8 examination of the plaintiff and prepare his expert report under the current scheduling order. In
9 addition, the plaintiff recently had to undergo surgery, for which the time she needs for recuperation
10 makes her inaccessible for an extended period of time to both defendant’s and plaintiff’s potential
11 experts. A modification of the pretrial schedule is imperative in order for the parties to complete the
12 expert-related discovery.
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IT IS SO STIPULATED.

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Respectfully submitted,

15 DATED: July 18, 2017

PHILLIP A. TALBERT
United States Attorney

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/s/ Bobbie J. Montoya

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BOBBIE J. MONTOYA
Assistant United States Attorney

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Attorneys for Defendant
United States of America

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MASTRANGELO LAW OFFICES

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/s/ Nicholas J. Mastrangelo (auth’d 7/18/17)

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NICHOLAS J. MASTRANGELO

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Attorney for Plaintiff
Judy Munshower

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Amended Stipulation and [Proposed] Order to Extend
Pretrial Schedule Deadlines

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ORDER

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Finding good cause, the foregoing stipulation between the parties is hereby APPROVED. The

3 deadlines set forth in the Status (Pretrial Scheduling) Order, ECF 11, are extended as follows:
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Expert disclosure:

October 31, 2017

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Rebuttal expert disclosure:

November 30, 2017

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Discovery cutoff:

January 31, 2018

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Dispositive motion filing:

March 13, 2018

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Dispositive hearing:

April 10, 2018 at 1:30 p.m.

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Joint pretrial statement due: May 18, 2018

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Final pretrial conference:

May 25, 2018 at 10:00 a.m.

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Trial:

July 9, 2018 at 9:00 a.m.

12 In all other respects, the scheduling set forth in the December 14, 2016 Status (Pretrial Scheduling)
13 Order and its all of its other provisions shall remain in full force and effect.
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IT IS SO ORDERED.

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16 DATED: 7/18/2017
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/s/ John A. Mendez_____________
JOHN A. MENDEZ
United States District Court Judge

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Amended Stipulation and [Proposed] Order to Extend
Pretrial Schedule Deadlines

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