Deppe et al v. Shasta County et al

Filing 21

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/1/2022 MODIFYING the 5 Pretrial Scheduling Order as follows: Close of Fact Discovery is 6/30/2023. Expert Disclosure due by 8/25/2023. Rebuttal Expert Disclosures due by 9/29/2023. Close of Expert Discovery due by 10/27/2023. Dispositive Motions filed by 11/27/2023. Joint Notice of Trial Readiness due by 10/27/2023. (Coll, A)

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MICHAEL J. HADDAD (SBN 189114)
JULIA SHERWIN (SBN 189268)
TERESA ALLEN (SBN 264865)
BRIAN HAWKINSON (SBN 341856)
HADDAD & SHERWIN LLP
505 Seventeenth Street
Oakland, CA 94612
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JORDAN DEPPE, Deceased, by and through his
Successor in Interest, MICHAEL DEPPE; and
MICHAEL DEPPE, Individually,

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Plaintiff,
vs.
SHASTA COUNTY, a public entity; SHASTA
COUNTY SHERIFF-CORONER ERIC MAGRINI,
in his individual capacity; CAPTAIN GENE
RANDALL; WELLPATH INC., a Delaware
corporation; WELLPATH MANAGEMENT, INC.,
a Delaware Corporation; WELLPATH LLC, a
Delaware Limited Liability Company;
CALIFORNIA FORENSIC MEDICAL GROUP,
INC., a California Corporation; SANAZ PARSA,
M.D.; TRACI LEWIS, L.M.F.T; SHEA PHINNEY,
L.M.F.T.; DANIEL DELLWO, P.A.; and DOES 1–
20; individually, jointly and severally,
Defendants.

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Case No. 2:22-cv-00187-TLN-JDP
STIPULATION AND ORDER TO
MODIFY SCHEDULING ORDER
(Doc. 5)

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Case No.: 2:22-cv-00187-TLN-JDP: STIP. AND (PROPOSED) ORDER TO MODIFY SCHEDULING ORDER

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Pursuant to the Court’s instruction on May 20, 2022, after the parties filed their Joint Case
Management Statement (Doc. 17), the parties hereby stipulate and agree to modify the Scheduling
Order in this matter (Doc. 5) as follows:
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This is a civil rights wrongful death/survival action arising from allegations of the

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Defendants’ deliberate indifference to the serious medical and mental health needs of pretrial

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detainee, Jordan Deppe, resulting in his suicide on January 7, 2021, at the Shasta County jail, with a

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date of death of January 8, 2021.

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2.

This case involves a large number of participants, including six currently known

individual defendants and five entity defendants, represented by three sets of counsel. Based on the

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complexities of the issues presented, the number of parties, records involved, and anticipated
depositions, an additional amount of time is needed to accommodate the schedules of all parties and

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deponents, to allow for the completion of discovery and expert disclosures, to allow the experts time

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to complete their review of deposition transcripts before writing their reports, and to allow sufficient

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time for pretrial preparation.

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3.

While all parties have agreed that the proposed modifications will allow the parties

additional time to adequately prepare for trial, the parties are mindful of the overcrowded Eastern
District docket, the demands placed on Eastern District judges, and the Court’s limited resources,

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especially during this pandemic. The parties are represented by experienced counsel who have

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worked together before, sometimes on many cases, and will continue to work cooperatively

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together, and in an orderly fashion, and believe that they will complete all necessary discovery and

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pretrial matters with this extension of the deadlines.

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Case No.: 2:22-cv-00187-TLN-JDP: STIP. AND ORDER TO MODIFY SCHEDULING ORDER

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4.

The parties therefor stipulate to an extension of the dates in this matter. The

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modification of the discovery, dispositive motion, and pretrial dates, as requested in the parties’

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Joint Case Management Statement (Doc. 17), would move dates as follows:

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Event

New Date

Close of Fact Discovery

December 28, 2022

June 30, 2023

Expert Disclosures due

February 24, 2023

August 25, 2023

Rebuttal Expert Disclosures

March 28, 2023

September 29, 2023

Close of Expert Discovery

Counsel are instructed to
complete all discovery of
expert witnesses in a timely
manner in order to comply
with the Court's deadline for
filing dispositive motions.
January 26, 2023

October 27, 2023

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Current Date

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Dispositive Motion filing
deadline

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Joint Notice of Trial Readiness April 27, 2023

July 27, 2023
October 27, 2023

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For the foregoing reasons, the parties respectfully request that this Court enter an order
extending the discovery, dispositive motion, and pretrial dates in this case as set forth above, and
pursuant to the parties’ Joint Case Management Statement.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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Dated: May 31, 2022

HADDAD & SHERWIN LLP

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/s/ Teresa Allen

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TERESA ALLEN
Attorneys for Plaintiff

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Case No.: 2:22-cv-00187-TLN-JDP: STIP. AND ORDER TO MODIFY SCHEDULING ORDER

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Dated: May 31, 2022

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MANNING & KASS
ELLROD, RAMIREZ, TRESTER LLP
/s/ Lynn L. Carpenter

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MILDRED K. O’LINN
LYNN L. CARPENTER
KAYLEIGH A. ANDERSEN
Attorneys for Defendants
SHASTA COUNTY, SHERIFF-CORONER ERIC
MAGRINI, and CAPTAIN GENE RANDALL

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Dated: May 31, 2022

BERTLING LAW GROUP, INC.

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/s/ Jemma Parker Saunders

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PETER BERTLING
JEMMA PARKER SAUNDERS
Attorneys for Defendants
WELLPATH INC., WELLPATH MANAGEMENT,
INC., WELLPATH LLC, CALIFORNIA FORENSIC
MEDICAL GROUP INC., TRACY LEWIS, L.M.F.T.,
SHEA PHINNEY, L.M.F.T., and DANIEL DELLWO,
P.A.

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Dated: May 31, 2022

LAURIA TOKUNAGA GATES & LINN, LLP

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/s/ Anthony Lauria

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ANTHONY LAURIA
Attorneys for Defendant SANAZ PARSA, M.D.

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Case No.: 2:22-cv-00187-TLN-JDP: STIP. AND ORDER TO MODIFY SCHEDULING ORDER

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ORDER

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Based on the parties’ stipulation, and with good cause appearing,
IT IS HEREBY ORDERED that the Pretrial Scheduling Order (Doc. 5) is modified as
follows:
Event

Current Date

New Date

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Close of Fact Discovery

December 28, 2022

June 30, 2023

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Expert Disclosures due

February 24, 2023

August 25, 2023

Rebuttal Expert Disclosures

March 28, 2023

September 29, 2023

Close of Expert Discovery

Counsel are instructed to
complete all discovery of
expert witnesses in a timely
manner in order to comply
with the Court's deadline for
filing dispositive motions.
January 26, 2023

October 27, 2023

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Dispositive Motion filing
deadline

Joint Notice of Trial Readiness April 27, 2023

November 27, 2023
October 27, 2023

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All other dates set forth in Doc. No. 5 will remain the same.
IT IS SO ORDERED.

Dated: June 1, 2022
Troy L. Nunley
United States District Judge

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Case No.: 2:22-cv-00187-TLN-JDP: STIP. AND ORDER TO MODIFY SCHEDULING ORDER

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