R.H., et al., v. City of Redding

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Dennis M. Cota on 7/19/2021 EXTENDING the Discovery dates as follows: Discovery due by 10/15/2021; Expert Disclosure due by 9/10/2021 and Rebuttal due by 9/27/2021. (Tupolo, A)

Case 2:20-cv-01435-WBS-DMC Document 20 Filed 07/19/21 Page 1 of 4
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DALE L. ALLEN, JR., State Bar No. 145279
[e-mail]
KEVIN P. ALLEN, State Bar No. 252290
[e-mail]
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
180 Montgomery Street, Suite 1200
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
CITY OF REDDING, JOE ROSSI, JAY GUTERDING, and
BRETT LEONARD
UNITED STATES DISTRICT COURT

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ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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EASTERN DISTRICT OF CALIFORNIA

180 Montgomery Street, Suite 1200
San Francisco, California 94104

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R.H., a minor, by and through her
Case No. 2:20-CV-01435-WBS-DMC
guardian ad litem, Sheila Brown;
ESTATE OF ERIC JAY HAMES, by and STIPULATION AND ORDER TO EXTEND
through its personal representative, Crystal DISCOVERY DATES
Dunlap-Bennett,
Plaintiff,

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v.

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CITY OF REDDING, a public entity; JOE
ROSSI, an individual; KIP KINNEAVY,
an individual; JAY GUTERDING, an
individual; BRETT LEONARD, an
individual; and DOES 5 through 20
inclusive,

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Defendants.

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451599.1

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STIPULATION & [PROPOSED] ORDER
2:20-CV-01435-WBS-DMC

Case 2:20-cv-01435-WBS-DMC Document 20 Filed 07/19/21 Page 2 of 4
IT IS HEREBY STIPULATED, and respectfully requested, by and between Plaintiffs

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R.H., a minor, by and through her guardian ad litem, Sheila Brown, and ESTATE OF ERIC JAY

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HAMES, by and through its personal representative, Crystal Dunlap-Bennet (hereinafter,

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collectively “Plaintiffs”) and Defendants CITY OF REDDING, JOE ROSSI, KIP KINNEAVY,

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JAY GUTERDING and BRETT LEONARD (hereinafter, collectively “Defendants”) by and

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through their designated counsel, that:

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WHEREAS, on July 17, 2020, Plaintiffs filed their Complaint (Dkt. No. 1);

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WHEREAS, on August 10, 2020, Plaintiffs filed their First Amended Complaint (Dkt.

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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No. 8);
WHEREAS, on September 14, 2020, Defendants City of Redding, Joe Rossi, Jay

180 Montgomery Street, Suite 1200
San Francisco, California 94104

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Guterding and Brett Leonard filed their Answer (Dkt. No. 10);
WHEREAS, on November 13, 2020, Defendant Kip Kinneavy filed his Answer (Dkt. No.

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14);
WHEREAS, on November 16, 2020, the Court issued the Pre-Trial Scheduling Order
(Dkt. No. 16);
WHEREAS, the Parties did proceed as best able by Zoom depositions, but have been
delayed in retaining and completing discovery because of Covid;
WHEREAS, counsel for Defendants City of Redding, Joe Rossi, Jay Guterding and Brett

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Leonard, Mr. Dale Allen, and counsel for Plaintiffs, Mr. Neil Gehlawat, are completing expert

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depositions in a trial set for August 17, 2021 in Shasta Superior Court with Judge Stephen Baker

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further causing delays in completing discovery;

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451599.1

WHEREAS, this is the first request for an extension on the case management schedule
and for the limited purposes of continuing discovery dates;
WHEREAS, the current discovery schedule is set as:
Discovery Cut-Off:
(Inclusive of all expert depositions)

September 24, 2021

Expert Witness Disclosures:

July 30, 2021

Rebuttal Expert Witness Disclosures:

August 27, 2021; and

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STIPULATION & [PROPOSED] ORDER
2:20-CV-01435-WBS-DMC

Case 2:20-cv-01435-WBS-DMC Document 20 Filed 07/19/21 Page 3 of 4
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WHEREAS, the Parties met and conferred and agreed to extend discovery dates and set
the case schedule as proposed below:
Discovery Cut-Off:
(Inclusive of all expert depositions)

October 15, 2021

Expert Witness Disclosure:

September 10, 2021

Rebuttal Expert Witness Disclosure:

September 27, 2021

IT IS SO AGREED.
Dated: July 14, 2021

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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By: /s/ Neil K. Gehlawat
NEIL K. GEHLAWAT
Attorneys for Plaintiffs
R.H., a minor, by and through her guardian ad
litem, Sheila Brown; ESTATE OF ERIC JAY
HAMES, by and through its personal
representative, Crystal Dunlap-Bennett,

180 Montgomery Street, Suite 1200
San Francisco, California 94104

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Dated: July 14, 2021

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By: /s/ Dale L. Allen, Jr.
DALE L. ALLEN, JR.
Attorneys for Defendants
CITY OF REDDING, JOE ROSSI, JAY
GUTERDING, AND BRETT LEONARD

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Dated: July 14, 2021

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By: /s/ Gary G. Goyette
GARY G. GOYETTE
Attorney for Defendant
KIP KINNEAVY

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IT IS SO ORDERED.
Dated: July 19, 2021

____________________________________
DENNIS M. COTA
UNITED STATES MAGISTRATE JUDGE

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451599.1

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STIPULATION & [PROPOSED] ORDER
2:20-CV-01435-WBS-DMC

Case 2:20-cv-01435-WBS-DMC Document 20 Filed 07/19/21 Page 4 of 4
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ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

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451599.1

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STIPULATION & [PROPOSED] ORDER
2:20-CV-01435-WBS-DMC