Baldizon et al v. California Department of Corrections and Rehabilitation et al

Filing 47

STIPULATION and ORDER for extension 46 signed by Senior Judge William B. Shubb on 4/13/2018: Plaintiff may file a further Amended Complaint or other pleading no later than 5/11/2018. Initial Expert Witness Disclosures are due by 11/30/2018. Rebuttal Expert Witness Disclosures are due by 1/30/2019. The discovery cut-cut off is extended to 4/1/2019. All other dates remain the same. (Kirksey Smith, K)

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Kresta Nora Daly, SBN 199689

BARTH DALY LLP
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431 "I" Street, Suite 201
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiffs

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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B ARTH D ALY

LLP
A TTORNEYS A T L AW
S ACRAMENTO , C ALIFORNIA

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JANETTE RAMIREZ, individually and as a
representative of the Estate of ROBERTO
BALDIZON, Deceased; ANA
JUSCAMAITA, individually and as a
representative of the Estate of ROBERTO
BALDIZON, Deceased; and THE ESTATE
OF ROBERTO BALDIZON,

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STIPULATION AND [PROPOSED]
ORDER

Plaintiffs,

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Case No. 2:17-CV-00228-WBS-AC

v.
JEFFREY MACOMBER, individually and in
his official capacity as Former Warden of
California State Prison-Sacramento and
DOES 1 through 100, inclusive, in their official
and personal/individual capacities,

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Defendants.

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Plaintiffs Janette Baldizon and Ana Juscamaita, and Defendant Macomber, through their

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counsel, stipulate as follows:
1. This court previously ordered an amended complaint be filed no later than April 13,

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2018;

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2. In the interim plaintiffs’ counsel obtained and reviewed certain records in anticipation

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of filing an amended complaint;

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3. Plaintiffs’ counsel requires additional time to confer with her clients regarding the

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{00024549}

STIPULATION AND [PROPOSED] ORDER

-1-

CASE NO. 2:17-CV-00228-WBS-AC

information contained in those records. As such Plaintiffs are requesting four
additional weeks prior to filing an amended complaint or other pleading;
4. The parties wish to make the following changes to the previous scheduling order:
a. Initial Expert Witness Disclosures Due November 30, 2018;
b. Rebuttal Expert Witness Disclosures Due January 30, 2019;
c. Discovery Cut-Off March 30, 2019; and
d. All other dates not specifically addressed herein remain the same.
5. A further amended complaint or other pleading shall be filed by Plaintiff no later than
May 11, 2018.
6. Defendants do not object.
Dated: April 12, 2018.

Respectfully submitted,
BARTH DALY LLP
By

Dated: April 12, 2018.

/s/ Kresta Nora Daly
KRESTA NORA DALY
Attorneys for Plaintiffs

Respectfully submitted,
XAVIER BECERRA
ATTORNEY GENERAL OF CALIFORNIA
By

/s/ R. Lawrence Bragg
R. LAWRENCE BRAGG
Supervising Deputy Attorney General
Attorneys for Defendant Macomber

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{00024549}
OPPOSITION TO MOTION FOR APPOINTMENT OF RECEIVER

ORDER
In light of the stipulation of the parties, and good cause appearing, it is ordered that
Plaintiff may file a further Amended Complaint or other pleading no later than May 11, 2018, that
Initial Expert Witness Disclosures are due by November 30, 2018, that Rebuttal Expert Witness
Disclosures are due by January 30, 2019, that the discovery cut-cut off is extended to April 1,
2019; and all other dates not specifically addressed herein remain the same.
Dated: April 13, 2018

{00024549}
OPPOSITION TO MOTION FOR APPOINTMENT OF RECEIVER