Blankership v. City of Sacramento

Filing 20

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 6/5/24 CONTINUING the initial expert disclosure deadline to 11/18/24, the rebuttal expert disclosure deadline to 12/16/24, the expert discovery deadline to 2/7/25 and the dispositive motion deadline to 3/10/25. All other discovery deadlines and motion deadlines shall remain unchanged. (Kastilahn, A)

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SUSANA ALCALA WOOD, City Attorney (SBN 156366)
DAVID J. GIBSON, Senior Deputy City Attorney (SBN 272516)
[e-mail]
CITY OF SACRAMENTO
915 I Street, Room 4010
Sacramento, CA 95814-2608
Telephone: [phone]
Facsimile: [phone]
Attorneys for the CITY OF SACRAMENTO
MARK P. VELEZ, ESQ. (SBN 163484)
NATALYA V. GRUNWALD, ESQ. (SBN 265084)
THE VELEZ LAW FIRM, PC
3010 Lava Ridge Court, Suite 120
Roseville, California 95661
Telephone: (916) 774 – 2720
Facsimile: (916) 774 – 2730
Attorneys for Plaintiff
ADAM BLANKENSHIP

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Case No.: 2:23-cv-00610-KJM-CKD

ADAM BLANKENSHIP,

STIPULATION AND ORDER TO
EXTEND EXPERT DISCOVERY AND
DISPOSITIVE MOTION DEADLINES

Plaintiff,
vs.
CITY OF SACRAMENTO,
Defendant.

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The Parties, Plaintiff Adam Blankenship and Defendant City of Sacramento hereby

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stipulate, through their respective counsel of record, to the below based upon the following

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good cause:

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///

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///

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STIPULATION AND ORDER

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1. Existing Due Date and Deadlines and Proposed New Deadlines (per Document
4-1 (“Standing Order”), No. 8 (A)).

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Current Deadline

Proposed New Deadline

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Initial Expert Disclosure

June 24, 2024

November 18, 2024

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Rebuttal Witness Disclosure

July 15, 2024

December 16, 2024

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Expert Discovery Close

October 21, 2024

February 7, 2025

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Dispositive Motion Deadline

November 20, 2024

March 10, 2025

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Trail Date

Not Set

Not Set

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2. Good Cause for Granting the Extension (per Standing Order No. 8 (B):

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The Parties have diligently pursued discovery. Each party has conducted written

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discovery, including interrogatories and requests for production of documents, and the parties

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are in the process of conducting fact depositions, including depositions of Plaintiff’s medical

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treaters, which are not yet completed. Those treaters were not discovered until Plaintiff’s

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deposition which took place on May 10 and May 14, 2024. The parties are also in process of

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reviewing other witness deposition transcripts, some of which are not yet available. The parties

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each need to complete fact discovery and have the transcripts in order to interview, select, and

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prepare expert witnesses.

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Additionally, the parties are currently engaged in settlement discussions and preparing for

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an ADR session through the court-sponsored VDRP. The parties are working with neutral

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Terry Wills. The selected mediation date is September 12, 2024. This was the first mutually

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available date for counsel, clients, and Ms. Wills. Moving the expert witness discovery

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deadlines until after mediation will facilitate settlement by eliminating potential significant

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expert witness costs for each party.

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The Parties have agreed to the modification of the discovery schedule in section 1 above.

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3. Prior Requests for Extensions (per Standing Order No. 8 (C): The parties jointly

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made one (1) request for a discovery extension in this matter, on April 18, 2024. (See
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STIPULATION AND ORDER

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Document 17, “Stipulation and Proposed Order to Extend Discovery Deadline”). In the prior

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request, the Court granted the request to extend the fact discovery deadline from May 10, 2024

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to June 10, 2024, and to extend the initial expert disclosure deadline from June 17, 2024 to

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June 24, 2024. The extension was granted.

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DATED: May 30, 2024

THE VELEZ LAW FIRM, PC

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By:

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Attorneys for Plaintiff
ADAM BLANKENSHIP

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/s/Natalya V. Grunwald
NATALYA V. GRUNWALD

DATED: May 30, 2024

SUSANA ALCALA WOOD,
City Attorney

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By:

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/s/ DAVID J. GIBSON
DAVID J. GIBSON
Senior Deputy City Attorney
Attorneys for the
CITY OF SACRAMENTO

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ORDER
The Court, having reviewed the stipulation of the parties, finds good cause to order as
follows:
1. The initial expert disclosure deadline shall be continued from June 24, 2024 to
November 18, 2024.

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2. The rebuttal expert disclosure shall be continued from July 15, 2024 to
December 16, 2024.

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3. The expert discovery deadline shall be continued from October 21, 2024 to
February 7, 2025.

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4. The dispositive motion deadline shall be continued from November 20, 2024 to
March 10, 2025.

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STIPULATION AND ORDER

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5. All other discovery deadlines and motion deadlines shall remain unchanged.

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IT IS SO ORDERED.

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DATED: June 5, 2024.

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STIPULATION AND ORDER