White v. City of Sacramento et al

Filing 29

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 9/9/2020 MODIFYING the Scheduling Order as follows: Close of Discovery is 11/30/2020, Expert Disclosure due by 2/4/2021, Rebuttal Expert Disclosure due by 3/8/2021, and Dispositive Motion Deadline is 7/16/2021. (Huang, H)

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GAVRILOV & BROOKS
Ognian Gavrilov, Esq., CSB No.: 258583
Kalle E. Mikkola, Esq., CSB No.: 307203
2315 Capitol Avenue
Sacramento, California 95816
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Jordan White
LONGYEAR & LAVRA, LLP
John A. Lavra, CSB No.: 114533
Amanda L. McDermott, CSB No.: 253651
3620 American River Drive, Suite 230
Sacramento, CA 95864
Phone: [phone]
Facsimile: 916-974-8510
Attorneys for Defendant County of Sacramento

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION
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) Case No.: 2:19-cv-00409-KJM-AC
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Plaintiff,
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) STIPULATION TO MODIFY
vs.
) SCHEDULING ORDER; ORDER
)
CITY OF SACRAMENTO; SACRAMENTO ) Complaint filed:
March 6, 2019
POLICE DEPARTMENT; COUNTY OF
)
SACRAMENTO; SACRAMENTO COUNTY )
SHERIFF’S DEPARTMENT,
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Defendants
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JORDAN WHITE,
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COMES NOW Plaintiff JORDAN WHITE and Defendant COUNTY OF
SACRAMENTO, by and through their respective counsel and subject to the approval of this
Court, hereby stipulate and respectfully request that this Court’s Pretrial Scheduling Order, be
modified to reflect new deadlines and cut-off dates as follows, or as to accommodate the Court’s
docket:

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STIPULATION TO MODIFY SCHEDULING ORDER; [PROPOSED] ORDER

Current Date

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New Date

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Close of Discovery:

September 30, 2020

November 30, 2020

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Expert Disclosure:

December 4, 2020

February 4, 2021

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Rebuttal Expert Disclosure:

January 8, 2021

March 8, 2021

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Dispositive Motion Deadline:

May 14, 2021

July 14, 2021

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Final Pretrial Conference:

TBD

TBD

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Trial:

TBD

TBD

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WHEREAS, the matter has not yet been set for Final Pretrial Conference or Trial;
WHEREAS, the parties attempted an early settlement conference, which was
unsuccessful;

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WHEREAS, counsel for all parties have met and conferred and agree that it would be in

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the interests of justice and judicial economy and that good causes exists for the modification of

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the scheduling order;

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WHEREAS, this stipulation is not being made for the purpose of delay, or any other
improper purpose;
WHEREAS, continuing the pretrial deadlines will not prejudice any party or their
counsel.

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IT IS SO STIPULATED.

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Dated: September 9, 2020

LONGYEAR, O’DEA & LAVRA, LLP
By: /s/ Amanda L. McDermott as authorized on 8/26/2020
JOHN A. LAVRA
AMANDA L. MCDERMOTT
Attorneys for Defendant County of Sacramento

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STIPULATION TO MODIFY SCHEDULING ORDER; [PROPOSED] ORDER

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Dated: August 26, 2020

GAVRILOV & BROOKS

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By:

/s/ Kalle Mikkola
OGNIAN GAVRILOV
KALLE MIKKOLA
Attorneys for Plaintiff Jordan White

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STIPULATION TO MODIFY SCHEDULING ORDER; [PROPOSED] ORDER

ORDER

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Having reviewed and considered the above stipulation, this scheduling order to modified

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to reflect the following deadlines:

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Close of Discovery:

November 30, 2020

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Expert Disclosure:

February 4, 2021

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Rebuttal Expert Disclosure:

March 8, 2021

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Dispositive Motion Deadline:

July 16, 2021

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Final Pretrial Conference:

TBD

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Trial:

TBD

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IT IS SO ORDERED.

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DATED: September 9, 2020.

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STIPULATION TO MODIFY SCHEDULING ORDER; [PROPOSED] ORDER