Barrera et al v. City of Woodland et al

Filing 64

STIPULATION and ORDER signed by District Judge John A. Mendez on 7/20/2021 MODIFYING the 60 Pretrial Scheduling Order such that FRCP 26(a)(2) disclosures shall be made by 8/20/2021, and FRCP 26(a)(2)(c) disclosures shall be made by 9/3/2021. (Coll, A)

Case 2:18-cv-00329-JAM-KJN Document 64 Filed 07/21/21 Page 1 of 3

1 TAYLOR & RING
John C. Taylor (SBN 78389)
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Neil K. Gehlawat (SBN 289388)
3 1230 Rosecrans Avenue, Suite 360
Manhattan Beach, CA 90266
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Telephone: [phone]
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THE LAW OFFICE OF THOMAS C. SEABAUGH
Thomas C. Seabaugh, Esq. (SBN 272458)
333 South Grand Ave, 42nd Floor
Los Angeles, CA 90071
Telephone: [phone]
[e-mail]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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16 DANIEL BARRERA, et al.

CASE NO. 2:18-cv-00329-JAM-KJN

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JOINT STIPULATION AND ORDER
ADJUSTING EXPERT DISCLOSURE
DEADLINES

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Plaintiffs,
vs.

20 CITY OF WOODLAND, et al.,
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Defendants.

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Case No. 2:18-cv-00329-JAM-KJN
JOINT STATUS REPORT

Case 2:18-cv-00329-JAM-KJN Document 64 Filed 07/21/21 Page 2 of 3

Joint Stipulation

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The parties hereby stipulate to and request an Order modifying the Pretrial Scheduling

3 Order (ECF No. 60) as to expert disclosures only, extending the deadlines by two weeks.
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A previous stipulation, which was granted, moved the deadlines by two weeks, and this

5 stipulation would add an additional two weeks, bringing the total departure from the original
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schedule to one month. This proposed change will not affect the September 24, 2021 discovery
deadline; the November 5, 2021, dispositive motion filing deadline; or trial set for April 11, 2022.
Currently, the parties are required to make Fed. R. Civ. P. 26(a)(2) expert witness
disclosures by August 6, 2021, and Fed. R. Civ. P. 26(a)(2)(c) supplemental and rebuttal expert
witness disclosures by August 20, 2021. The parties propose to move these two deadlines by two
weeks, such that Fed. R. Civ. P. 26(a)(2) disclosures shall be made by August 20, 2021, and Fed.
R. Civ. P. 26(a)(2)(c) disclosures shall be made by September 3, 2021.
The requested change is chiefly to accommodate the schedule of a non-party witness,

13 namely the coroner who performed the autopsy on the decedent in this case. This witness resides
14 out of state and has a busy schedule, which the parties wish to accommodate. However, the parties
15 wish to accomplish his deposition before disclosing expert reports. An extension would help the
16 parties avoid causing undue inconvenience or hardship to this third-party witness. The parties
17 submit that good cause exists to grant this extension because the parties agree, no party will be
18 prejudiced, the grounds are reasonable, and because the no other aspect of the pretrial schedule
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Case No. 2:18-cv-00329-JAM-KJN
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A proposed order is submitted below.

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2 SO STIPULATED.
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Dated: July 20, 2021

ANGELO, KILDAY & KILDUFF, LLP
s/ Derick E. Konz1
By:_________________________________
BRUCE A. KILDAY
DERICK E. KONZ
Attorneys for Defendants

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Dated: July 20, 2021

TAYLOR AND RING; LAW OFFICE OF
THOMAS C. SEABAUGH

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s/ Thomas C. Seabaugh
By:_________________________________
NEIL K. GEHLAWAT
THOMAS C. SEABAUGH
Attorneys for Plaintiffs

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Proposed Order

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The Pretrial Scheduling Order (ECF No. 60) is modified such that Fed. R. Civ. P. 26(a)(2)
disclosures shall be made by August 20, 2021, and Fed. R. Civ. P. 26(a)(2)(c) disclosures shall be
made by September 3, 2021.

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SO ORDERED.

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22 Dated: July 20, 2021
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/s/ John A. Mendez
THE HONORABLE JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

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Authorized via email 7/19/2021 at 1:49 pm.

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Case No. 2:18-cv-00329-JAM-KJN
JOINT STATUS REPORT