Williams v. County of Sacramento et al

Filing 50

ORDER signed by District Judge Troy L. Nunley on 1/19/2023 ORDERING Fact Discovery due by 4/12/2023. Expert Witness Disclosure due by 6/12/2023. Supplemental Expert Witness Disclosure, within 20 days after designationof expert witnesses, and Dispositive Motions filed by 11/13/2023.(Reader, L)

Case 2:20-cv-00598-TLN-KJN Document 50 Filed 01/19/23 Page 1 of 5

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A PROFESSIONAL CORPORATION
John R. Whitefleet, SBN 213301
Jennifer L. Thompson, SBN 337107
350 University Ave., Suite 200
Sacramento, California 95825
[e-mail]
[e-mail]
TEL: [phone]
FAX: [phone]
Attorney for Defendants
CITY OF RANCHO CORDOVA,
NATHAN DANIEL, JOSEPH ZALEC,
AND DEREK HUTCHINS
Van Longyear, SBN 84189
Nicole M. Cahill, SBN 287165 
LONGYEAR & LAVRA, LLP 
555 University Ave., Suite 280 
Sacramento, CA 95825 
Tel: [phone]  
Fax: [phone] 
Attorneys for Defendant
COUNTY OF SACRAMENTO
Lawrance A. Bohm, SBN 208716
Daniel T. Newman, SBN 314937
BOHM LAW GROUP, INC.
4600 Northgate Boulevard, Suite 210
Sacramento, CA 95834
TEL: [phone]
FAX: [phone]
Attorneys for Plaintiffs
THOMAS WILLIAMS
AND CARLOS WILLIAMS

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JOINT STIPULATION AND ORDER TO CONTINUE PRE-TRIAL DEADLINES

Case 2:20-cv-00598-TLN-KJN Document 50 Filed 01/19/23 Page 2 of 5

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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THOMAS WILLIAMS,

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Plaintiff,

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Case No. 2:20-cv-00598-TLN-KJN
Case No. 2:19-cv-02345-TLN-KJN
JOINT STIPULATION AND ORDER TO
CONTINUE PRE-TRIAL DEADLINES

v.

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COUNTY OF SACRAMENTO; CITY OF
RANCHO CORDOVA; NATHAN
DANIEL; JOSEPH ZALEC; DEREK
HUTCHINS and DOES 1 through 50
inclusive,
Defendants.

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__________________________________/

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CARLOS WILLIAMS

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Plaintiff

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v.
COUNTY OF SACRAMENTO;
RANCHO CORDOVA POLICE DEPARTMENT;
and DOES 1 through 50 inclusive,
Defendants.
_________________________________/

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Plaintiffs THOMAS WILLIAMS and CARLOS WILLIAMS (“Plaintiffs”) and Defendants

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COUNTY OF SACRAMENTO, CITY OF RANCHO CORDOVA, NATHAN DANIEL, JOSEPH

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ZALEC, AND DEREK HUTCHINS, (collectively “Defendants”), by and through their (“Parties”)

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counsel of record, hereby stipulate and request that the Court continue the discovery deadline for 30 days

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for the limited purpose of completing the defendant deputies’ depositions and 90 days for the limited

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purpose of facilitating the production of records pursuant to the Court’s January 6, 2023 Order [Dkt. Nos.
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JOINT STIPULATION AND ORDER TO CONTINUE PRE-TRIAL DEADLINES

Case 2:20-cv-00598-TLN-KJN Document 50 Filed 01/19/23 Page 3 of 5

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43 & 48]. The Parties further request the extension of the other pre-trial deadlines in this matter. Good

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cause exists for the requested continuance pursuant to Federal Rules of Civil Procedure Rule 16(d) based

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upon the following:

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1.

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discovery only.

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2.

On July 15, 2021, this Court consolidated the above-referenced cases with respect to

On October 5, 2021, in Case No. 2:20-cv-00598-TLN-KJN, this Court issued an Amended

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Pre-Trial Scheduling Order setting forth all pre-trial deadlines. The Court entered the same Order on

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October 26, 2021 in Case No. 2:19-cv-02345-TLN-KJN.

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3.

On April 6, 2022, this Court granted the Parties’ joint stipulation to extend the pre-trial

deadlines, which extended the fact discovery deadline to January 12, 2023.
4.

On January 4, 5, and 6, 2023, Plaintiffs began deposing Deputies Daniel, Zalec, and

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Hutchins. Those depositions, however, did not conclude. The Parties agreed to continue the Deputies’

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depositions until the end of January. The Parties request a 30-day extension of the discovery deadline for

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the limited purpose of completing the Deputies’ depositions.

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5.

Furthermore, on January 6, 2023, Magistrate Kendall Newman granted in part Defendant

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City of Rancho Cordova’s Motion to Compel and ordered Plaintiffs to produce additional financial records

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within 30 days. [Dkt. Nos. 43 in 2:19-cv-02345-TLN-KJN and 48 in 2:20-cv-00598-TLN-KJN].

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6.

The Parties also seek an extension of the pre-trial deadlines of 90 days for the limited

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purpose of facilitating the production of documents consistent with Judge Newman’s order and for the

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Parties to resolve any disputes related to said production.

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7.

Because the Parties anticipate sending the financial records and deposition transcripts to

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experts in this matter, the Parties request that expert disclosure dates and dispositive motions also be

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extended.

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8.

The Parties also agree to extend discovery for the limited purpose of having Plaintiffs’

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expert examine the physical camera that was in Deputy Daniel’s vehicle on the night of the incident and

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subsequently removed. The Parties request a 90-day extension of the discovery deadline for the limited

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purpose of arranging for Plaintiffs’ expert to examine the physical camera at Defense Counsel’s office.

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9.

The Parties, through their respective undersigned counsel, agree and hereby do stipulate to
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JOINT STIPULATION AND ORDER TO CONTINUE PRE-TRIAL DEADLINES

Case 2:20-cv-00598-TLN-KJN Document 50 Filed 01/19/23 Page 4 of 5

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respectfully request that the Court modify the scheduling order as follows:

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Event

Schedule

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Fact Discovery

January 12, 2023

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Proposed New Schedule
To complete the Deputies’
depositions: February 13,
2023
To
facilitate
production
pursuant to Judge Newman’s
January 6, 2023 Order and
Plaintiffs’
inspection
of
camera: April 12, 2023

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Expert Witness Disclosure
Supplemental Expert
Witness Disclosure

March 14, 2023
June 12, 2023
Within 20 days after designation
Remains unchanged
of expert witnesses

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Dispositive Motions

August 15, 2023

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November 13, 2023

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Dated: January 19, 2023

BOHM LAW GROUP, INC.

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By: /s/ Kelsey K. Ciarimboli (auth. 1/18/23)
Lawrence A. Bohm
Kelsey K. Ciarimboli
Daniel T. Newman
Attorney for Plaintiffs

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Dated: January 19, 2023

LONGYEAR & LAVRA, LLP

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By: /s/ Nicole M. Cahill (auth. 1/18/23)
Van Longyear
Nicole M. Cahill
Attorney for Defendant
COUNTY OF SACRAMENTO

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JOINT STIPULATION AND ORDER TO CONTINUE PRE-TRIAL DEADLINES

Case 2:20-cv-00598-TLN-KJN Document 50 Filed 01/19/23 Page 5 of 5

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Dated: January 19, 2023

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By: /s/ Jennifer L. Thompson
John R. Whitefleet
Jennifer L. Thompson
Attorney for Defendants
CITY OF RANCHO CORDOVA,
NATHAN DANIEL, JOSEPH ZALEC,
AND DEREK HUTCHINS

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ORDER

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Good cause having been shown, based on the foregoing Stipulation by the Parties, the Court hereby
ORDERS as follows:
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The pre-trial deadlines in this case shall be amended as follows:

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Event

Schedule

Fact Discovery

January 12, 2023

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To
facilitate
production
pursuant to Judge Newman’s
January 6, 2023 Order and
Plaintiff’s
inspection
of
camera: April 12, 2023

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Proposed New Schedule
To complete the Deputies’
depositions: February 13,
2023

Expert Witness Disclosure
Supplemental Expert
Witness Disclosure

March 14, 2023
June 12, 2023
Within 20 days after designation
Remains unchanged
of expert witnesses

Dispositive Motions

August 15, 2023

November 13, 2023

IT IS SO ORDERED.

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Dated: January 19, 2023
Troy L. Nunley
United States District Judge
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JOINT STIPULATION AND ORDER TO CONTINUE PRE-TRIAL DEADLINES