Feeney v. United States of America

Filing 14

STIPULATION and ORDER TO MODIFY SCHEDULING ORDER signed by District Judge John A. Mendez on 2/7/2020. Plaintiff's Expert Disclosures new date 4/24/2020. Defendant's Expert Disclosures new date 6/5/2020; Supplemental Expert Disclosures new d ate 6/25/2020; Discovery Cutoff new date 7/24/2020; Dispositive Motions new filing deadline 8/18/2020; Last Day for Dispositive Motions to be Heard 9/15/2020; The Final Pretrial Conference new date 10/16/2020 at 11:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. Bench Trial new date: 11/16/2020 at 09:00 AM in Courtroom 6 (JAM) before District Judge John A. Mendez. (Mena-Sanchez, L)

1 McGREGOR W. SCOTT
United States Attorney
2 CHI SOO KIM
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
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Attorneys for United States of America
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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KATIE FEENEY,

CASE NO. 2:17-cv-02303 JAM-AC
Plaintiff,

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v.

JOINT STIPULATION AND ORDER TO
MODIFY THE SCHEDULING ORDER [ECF
No. 11]

UNITED STATES OF AMERICA,
Defendant.

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Plaintiff Katie Feeney and Defendant United States respectfully propose and stipulate to modify

17 the current scheduling order as set forth below. Joint Stip. and Order to Modify the Status (Pre-trial
18 Scheduling) Order [ECF No. 11]. There is good cause to modify the schedule due to Plaintiff’s complex
19 medical condition, which includes disarticulation (i.e., amputation). In order to proceed with and
20 complete both fact and expert discovery, the parties agree that Plaintiff must undergo various medical
21 exams. Due to Plaintiff’s complex medical condition, which includes the coordination of medical care
22 with different physicians at different medical institutions across the country, additional medical
23 treatment and surgeries were undertaken. Plaintiff began her medical exams in the fall but was not able
24 to complete them due to her various medical complications, and the parties are currently re-scheduling
25 them. As a result, the parties respectfully request a modification of the scheduling order to allow the
26 parties to complete fact and expert discovery.
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The parties have been working together cooperatively and will continue to update the Court with

28 the case status. The parties are working towards an efficient resolution of this matter as required and
Feeney v. United States, No. 2:17-cv-02303 JAM-AC
JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER

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1 promoted in the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 1.
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Schedule

Current

Proposed

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-

Plaintiff’s Expert Disclosures

Jan. 6, 2020

April 24, 2020

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-

Defendant’s Expert Disclosures

Feb. 3, 2020

June 5, 2020

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-

Supplemental Expert Disclosures

Feb. 21, 2020

June 25, 2020

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-

Discovery Cutoff

March 20, 2020

July 24, 2020

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-

Dispositive Motion Filing Deadline

April 10, 2020

Aug. 18, 2020

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-

Last Day for Dispositive Motions to be Heard

May 12, 2020

Sep. 15, 2020

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-

Final Pretrial Conference

July 14, 2020

Oct. 16, 2020 at 11:00

Sep. 14, 2020

Nov. 16, 2020 at 9:00

a.m.

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-

Trial (Bench, 8 days)
a.m.

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Dated: February 6, 2020

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Respectfully submitted,
McGREGOR W. SCOTT
United States Attorney
By: /s/ Chi Soo Kim
Chi Soo Kim
Assistant United States Attorney

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Attorneys for the United States

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BOSTWICK & PETERSON, LLP

20 Dated: February 6, 2020
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/s/ James S. Bostwick
James S. Bostwick, Esq.

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Attorneys for Plaintiff Katie Feeney

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(auth’d 2/6/20)

ORDER
IT IS SO ORDERED.

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26 DATED: 2/7/2020
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/s/ John A. Mendez_________
JOHN A. MENDEZ
United States District Court Judge

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Feeney v. United States, No. 2:17-cv-02303 JAM-AC
JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY SCHEDULING ORDER

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