Cunningham v. United States of America

Filing 16

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/18/2020 MODIFYING the discovery, motion, and trial deadlines as follows: Plaintiff's Disclosure of Experts and Reports due by 6/4/2021; Defendant's Disclosure of Exper ts and Reports due by 7/9/2021; Rebuttal Expert Disclosure and Reports due by 8/6/2021; Discovery Cut-Off due by 9/10/2021; Motions to Compel Must Be Heard By 9/3/2021; Dispositive Motions shall be filed by 10/15/2021; Pretrial Conference SET for 1/31/2022 at 01:30 PM and the Jury Trial is SET for 3/29/2022 at 09:00 AM, BOTH in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Kastilahn, A)

1 McGREGOR W. SCOTT
United States Attorney
2 EDWARD A. OLSEN, CSBN 214150
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
5 [e-mail]
6 Attorneys for the United States of America
7 KIRK J. WOLDEN
CARTER WOLDEN CURTIS, LLP
8 1111 Exposition Boulevard, Suite 602
Sacramento, CA 95815
9 Telephone: [phone]
Facsimile: [phone]
10 [e-mail]
11 Attorneys for Plaintiff
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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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BRUCE CUNNINGHAM,

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CASE NO. 2:19-CV-01580-WBS-CKD
Plaintiff,

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v.

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UNITED STATES OF AMERICA,

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THIRD STIPULATION TO
EXTEND DISCOVERY, MOTION
AND TRIAL DEADLINES; AND
ORDER

Defendant.

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The parties to the above-captioned case hereby stipulate to again extend the discovery,

24 motion, and trial deadlines as follows in light of the COVID-19 public health emergency.
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Under the current Status (Pretrial Scheduling) Order, the pertinent deadlines are as follows:

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29 STIPULATION AND ORDER TO EXTEND DISCOVERY, MOTION, AND TRIAL DEADLINES
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Plaintiff’s Disclosure of Experts and Reports:

January 7, 2021

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Defendant’s Disclosure of Experts and Reports:

February 5, 2021

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Rebuttal Expert Disclosure and Reports:

March 5, 2021

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Discovery Cut-Off:

April 30, 2021

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Motions to Compel Must Be Heard By:

April 2, 2021

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Dispositive Motions Shall Be Filed By:

May 7, 2021

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Pretrial Conference:

August 16, 2021

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Trial:

October 13, 2021

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The current national health crisis related to the coronavirus has made thorough and complete

10 discovery, including the scheduling an independent medical evaluation, extremely difficult. In light
11 of this unprecedented situation, which will be of unknown duration, the parties submit that good
12 cause exists to modify the schedule. Based on the information currently available, including the fact
13 that the parties have stipulated to inclusion of this case in the Court’s Voluntary Dispute Resolution
14 Program (“VDRP”), the parties stipulate and respectfully request that the Court modify the
15 discovery, motion, and trial deadlines as follows:
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Plaintiff’s Disclosure of Experts and Reports:

June 4, 2021

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Defendant’s Disclosure of Experts and Reports:

July 9, 2021

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Rebuttal Expert Disclosure and Reports:

August 6, 2021

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Discovery Cut-Off:

September 10, 2021

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Motions to Compel Must Be Heard By:

September 3, 2021

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Dispositive Motions Shall Be Filed By:

October 15, 2021

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Pretrial Conference:

January 31, 2022, at 1:30 p.m.

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Trial:

March 29, 2022, at 9:00 a.m.

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29 STIPULATION AND ORDER TO EXTEND DISCOVERY, MOTION, AND TRIAL DEADLINES
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Respectfully submitted,

2 Dated: November 17, 2020

McGREGOR W. SCOTT
United States Attorney

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/s/ Edward A. Olsen
EDWARD A. OLSEN
Assistant United States Attorney
Attorneys for the United States

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9 Dated: November 17, 2020
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/s/ Kirk J. Wolden
Kirk J. Wolden
CARTER WOLDEN CURTIS, LLP
Attorneys for Plaintiff

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ORDER

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Pursuant to stipulation, IT IS SO ORDERED.
Dated: November 18, 2020

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29 STIPULATION AND ORDER TO EXTEND DISCOVERY, MOTION, AND TRIAL DEADLINES
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