Sykes, et al. v. Shea, et al.

Filing 11

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 5/24/17: The deadline to disclose experts and produce expert reports shall occur no later than August 17, 2017, and rebuttal reports shall be served on or before September 15, 2017. The deadline to conduct depositions of experts will be extended to October 13, 2017. Expert discovery shall be completed not later than October 31, 2017. (Kaminski, H)

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9701 Wilshire Blvd., 12th Floor
Beverly Hills, California 90212
Phone: [phone] Facsimile: [phone]

BANAFSHEH, DANESH & JAVID, PC

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BANAFSHEH, DANESH & JAVID, PC
SHAWN J. McCANN, ESQ. [SBN 227553]
[e-mail]
LAUREN E.S. HORWITZ, ESQ. [SBN 271858]
[e-mail]
NORMANDY KIDD, ESQ. [303921]
[e-mail]
9701 Wilshire Boulevard, 12th Floor
Beverly Hills, California 90212
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs, TYESHINA SYKES and JAE’LONIA SYKES,
by and through her guardian ad litem TYESHINA SYKES,
J. STEPHANIE KRMPOTIC, SBN 128671
LEEH A. DIBELLO, SBN 214349
LOW, BALL & LYNCH
505 Montgomery Street, 7th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Attorneys for Defendants and Counter-Claimants, DONALD JAMES SHEA,
an individual and KUNKEL TRUCK LINES, INC., a South Dakota Corporation
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA (SACRAMENTO DIVISION)

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TYESHINA SYKES, an individual; and
JAE’LONIA SYKES, by and through her
guardian ad litem TYESHINA SYKES, an
individual,

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Plaintiffs,

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vs.
DONALD JAMES SHEA, an individual;
KUNKEL TRUCK LINES, INC., a South
Dakota Corporation; and DOES 1-30;
Defendants.

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CASE NO.: 2:16-cv-02851-WBS-GGH
Hon. William B. Shubb

STIPULATION AND ORDER TO
CONTINUE EXPERT DISCOVERY
CUTOFF

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY CUTOFF
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Plaintiffs Tyeshina Sykes and Jae’Lonia Sykes, and Defendants Donald James Shea and

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Kunkle Truck Lines, Inc., by and through their respective counsel, hereby agree and stipulate as

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follows:

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1.

On April 7, 2017, the Court issued a Status (Pretrial Scheduling) Order, ordering

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the parties to disclose experts and produce expert reports in accordance with Federal Rule of

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Civil Procedure 26(a)(2) by no later than June 9, 2017, and rebuttal reports in accordance with

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Federal Rule of Civil Procedure 26(a)(2) on or before July 7, 2017. The Court also left

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discovery open until August 2, 2017. The Court also set the Final Pretrial Conference for

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December 4, 2017, and the Trial for February 6, 2017.

9701 Wilshire Blvd., 12th Floor
Beverly Hills, California 90212
Phone: [phone] Facsimile: [phone]

BANAFSHEH, DANESH & JAVID, PC

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2.

During the entire pendency of this lawsuit, the Parties have worked amicably and

diligently in an effort to complete discovery. The Parties are continuing to do so.
3.

The Parties agree that given the nature of the disputes in this particular case, it

would be appropriate to continue the deadlines associated with expert discovery.
4.

The Parties agree that the deadline to disclose experts and produce expert reports

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in accordance with Federal Rule of Civil Procedure 26(a)(2) should occur no later than August

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17, 2017, and rebuttal reports should be served in accordance with Federal Rule of Civil

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Procedure 26(a)(2) on or before September 15, 2017.

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5.

The Parties agree that the deadline to conduct depositions of experts should be

extended to October 13, 2017.
6.

The Parties agree that expert discovery shall be completed not later than October

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31, 2017. The word “completed” shall have the same meaning as outlined in the Court’s April

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7, 2017 Status (Pretrial Scheduling) Order.

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7.

The Parties agree that expert discovery/motions relating to experts shall be

completed not later than October 31, 2017.

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8.

No other pending dates in this matter need to be moved at this time.

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THEREFORE THE PARTIES AGREE AND STIPULATE to continue the deadline

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to disclose experts and produce expert reports in accordance with Federal Rule of Civil

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Procedure 26(a)(2) by no later than August 17, 2017, and rebuttal reports on or before

_____________________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY CUTOFF
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September 15, 2017. The parties also agree that the deadline to conduct depositions of experts

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will be extended to October 13, 2017. The deadline to complete expert discovery should be

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October 31, 2017. All other dates remain as currently calendared.

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The parties herein agree this stipulation may be signed in counterpart.

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DATED: May ____, 2017

BANAFSHEH, DANESH & JAVID, PC

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By

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9701 Wilshire Blvd., 12th Floor
Beverly Hills, California 90212
Phone: [phone] Facsimile: [phone]

BANAFSHEH, DANESH & JAVID, PC

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_________________________________
SHAWN J. McCANN
LAUREN E.S. HORWITZ
NORMANDY KIDD
Attorneys for Plaintiffs and Counter-Defendant
Tyeshina Sykes

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DATED: May ____, 2017

LOW, BALL & LYNCH

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By

___________________________
J. STEPHANIE KRMPOTIC
LEEH A. DIBELLO
Attorneys for Defendants
DONALD JAMES SHEA, an individual and
KUNKEL TRUCK LINES, INC., a South Dakota
Corporation

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_____________________________________________________________________________________________
STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY CUTOFF
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ORDER

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The Court having read the foregoing Stipulation and good cause appearing therefore, IT

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IS HEREBY ORDERED that the deadline to disclose experts and produce expert reports in

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accordance with Federal Rule of Civil Procedure 26(a)(2) shall occur no later than August 17,

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2017, and rebuttal reports shall be served in accordance with Federal Rule of Civil Procedure

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26(a)(2) on or before September 15, 2017. The deadline to conduct depositions of experts will

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be extended to October 13, 2017. Expert discovery shall be completed not later than October 31,

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2017. The word “completed” shall have the same meaning as outlined in the Court’s April 7,

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2017 Status (Pretrial Scheduling) Order.

9701 Wilshire Blvd., 12th Floor
Beverly Hills, California 90212
Phone: [phone] Facsimile: [phone]

BANAFSHEH, DANESH & JAVID, PC

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Additional Order

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Under no circumstances shall the above extension of expert discovery affect the cutoff

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date for dispositive motions, nor shall it in any way affect the requirement of filing pretrial

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statements as previously ordered.

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IT IS SO ORDERED.
Dated: May 24, 2017
/s/ Gregory G. Hollows
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE EXPERT DISCOVERY CUTOFF
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