Crone v. Tracy Unified School District et al

Filing 21

ORDER signed by Senior Judge John A. Mendez on 11/18/2022 ORDERING Dispositive Motions filed by 6/9/2023, Motion Hearing set for 7/25/2023 at 1:30. Expert Discovery due by 4/27/2023. Expert Witness Disclosures due by 2/17/2023, Supplemental Rebuttal Expert Witness Disclosures by 3/9/2023. Final Pretrial Conference set for 9/22/2023 at 11:00 AM in Courtroom 6 (JAM) before Senior Judge John A. Mendez, and Trial set for 11/6/2023 at 09:00 AM in Courtroom 6 (JAM) before Senior Judge John A. Mendez.(Reader, L)

Case 2:20-cv-01451-JAM-AC Document 21 Filed 11/21/22 Page 1 of 4

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Attorneys for DEFENDANT:
TRACY UNIFIED SCHOOL DISTRICT

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

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1545 RIVER PARK DRIVE, SUITE 204
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

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KELLIE M. MURPHY, ESQ. (SBN 189500)
KRISTEN M. CAPRINO, ESQ. (SBN 306815)
JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation
Point West Commerce Centre
1545 River Park Drive, Suite 204
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail] / [e-mail]

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)
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Plaintiff,
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v.
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TRACY UNIFIED SCHOOL DISTRICT and )
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BRIAN STEPHENS, an individual,
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Defendants.
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CHRISTOPHER CRONE,

CASE NO. 2:20-cv-01451-JAM-AC
STIPULATION TO MODIFY
SCHEDULING ORDER; ORDER

Complaint Filed:
Trial Date:

July 20, 2020
July 24, 2023

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Pursuant to Local Rule 144, Plaintiff Christopher Crone (“Plaintiff”) and Defendant

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Tracy Unified School District (“the District”) (collectively “the Parties”), by and through their

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attorneys of record,1 hereby stipulate as follows:
WHEREAS, on November 8, 2021, this Court issued a Scheduling Order [ECF No. 17]

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in this matter, a portion of which was changed by Minute Order dated November 17, 2021.

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The only claim alleged against Defendant Brian Stephens was dismissed with prejudice by Order dated
December 7, 2020 [ECF No. 13]; accordingly, the only remaining parties are Plaintiff and the District.

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STIPULATION TO MODIFY SCHEDULING ORDER; ORDER

Case 2:20-cv-01451-JAM-AC Document 21 Filed 11/21/22 Page 2 of 4

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written discovery recently propounded by Plaintiff and Plaintiff’s deposition scheduled for

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December 5, 2022.

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completion of the discovery outlined above, including a possible mediation, and defer additional

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discovery to avoid incurring additional fees and costs that may not be necessary.

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

WHEREAS, the Parties believe that a Settlement Conference, scheduled in the next three

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to four months, would be beneficial in the event the Parties’ efforts at resolution are not

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successful.

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1545 RIVER PARK DRIVE, SUITE 204
SACRAMENTO, CA 95815

WHEREAS, the Parties desire to discuss possible resolution of the matter after

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JOHNSON SCHACHTER & LEWIS

WHEREAS, the Parties have proceeded and are proceeding with discovery, including

WHEREAS, in light of the above, the Parties believe that an approximate three month

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extension of the deadlines previously set is reasonable and necessary. No prior extensions of

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these deadlines have been sought.

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THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED by the Parties that

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the Scheduling Order [ECF No. 17] be modified as follows (or with dates after those set forth

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below that are convenient for the Court):

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DISPOSITIVE MOTION FILING DEADLINE: June 9, 2023 (continued from
3/10/2023);

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DISPOSITIVE MOTION HEARING: July 25, 2023 (continued from 4/25/2023)

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DISCOVERY: April 27, 2023 (continued from 1/27/2023)

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EXPERT WITNESS DISCLOSURES: February 17, 2023 (continued from 11/18/2022)

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SUPPLEMENTAL/REBUTTAL EXPERT WITNESS DISCLOSURES: March 9, 2023

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(continued from 12/9/2022)

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FINAL PRETRIAL CONFERENCE: September 11, 2023 (continued from 6/9/2023)

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TRIAL: November 6, 2023 (continued from 7/24/2023)

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[SIGNATURES ON FOLLOWING PAGE]

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STIPULATION TO MODIFY SCHEDULING ORDER; ORDER

Case 2:20-cv-01451-JAM-AC Document 21 Filed 11/21/22 Page 3 of 4

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IT IS SO STIPULATED.

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Dated: November 18, 2022

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JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation
/s/ Kellie M. Murphy
KELLIE M. MURPHY

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Dated: November 18, 2022

LEIGH LAW GROUP, P.C.
/s/ _Jay T. Jambeck__ (authorized on 11/18/22)
JAY T. JAMBECK

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

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1545 RIVER PARK DRIVE, SUITE 204
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

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ORDER

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PURSUANT TO THE STIPULATION AND GOOD CAUSE APPEARING, the

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Court Orders that the dates set forth in the Scheduling Order previously issued in this case on

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November 8, 2021 shall be modified as follows:

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DISPOSITIVE MOTION FILING DEADLINE: June 9, 2023;

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DISPOSITIVE MOTION HEARING: July 25, 2023 at 1:30 p.m.;

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EXPERT DISCOVERY: April 27, 2023;

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EXPERT WITNESS DISCLOSURES: February 17, 2023;

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SUPPLEMENTAL/REBUTTAL EXPERT WITNESS DISCLOSURES: March 9, 2023;

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FINAL PRETRIAL CONFERENCE: September 22, 2023 at 11:00 a.m.; and

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TRIAL: November 6, 2023 at 9:00 a.m.

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This matter is REFERRED to Magistrate Judge Jeremy D. Peterson for settlement

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proceedings. The parties shall contact Judge Peterson’s Courtroom Deputy to obtain available

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dates for a settlement conference.

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STIPULATION TO MODIFY SCHEDULING ORDER; ORDER

Case 2:20-cv-01451-JAM-AC Document 21 Filed 11/21/22 Page 4 of 4

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IT IS SO ORDERED.

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Dated: November 18, 2022

/s/ John A. Mendez
THE HONORABLE JOHN A. MENDEZ
SENIOR UNITED STATES DISTRICT JUDGE

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TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

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1545 RIVER PARK DRIVE, SUITE 204
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

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STIPULATION TO MODIFY SCHEDULING ORDER; ORDER