Palomino v. California Forensic Medical Group et al

Filing 56

ORDER by Chief Magistrate Judge Maria-Elena James granting 53 Stipulation extending deadlines for Expert Disclosures and Expert Discovery. (rmm2S, COURT STAFF) (Filed on 12/6/2012)

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Gregory G. Spaulding, Esq. (SBN 106606)
Terry S. Sterling, Esq. (SBN 106379)
SPAULDING McCULLOUGH & TANSIL LLP
90 South E Street, Suite 200
P.O. Box 1867
Santa Rosa, CA 95402
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]; [e-mail]
Attorneys for Defendants COUNTY OF SONOMA,
SHERIFF BILL COGBILL and JOSHUA CLAASSEN
(incorrectly sued herein as DEPUTY "CLAUSEN")

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JULIO PALOMINO,
Plaintiff,

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Case No.: 11-CV-1329 MEJ

vs.
CALIFORNIA FORENSIC MEDICAL GROUP,
DR. TAYLOR FITHIAN, COUNTY OF
SONOMA, SHERIFF BILL COGBILL,
DEPUTY "CLAUSEN" AND DOES 1-10,

STIPULATION AND [PROPOSED] ORDER
EXTENDING DEADLINES FOR EXPERT
DISCLOSURES AND EXPERT
DISCOVERY

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Defendants.
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Plaintiff JULIO PALOMINO and defendants COUNTY OF SONOMA, SHERIFF BILL

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COGBILL and JOSHUA CLAASSEN (incorrectly sued herein as DEPUTY "CLAUSEN") hereby

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enter into this Stipulation Extending Deadlines For Expert Disclosures and Expert Discovery with

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reference to the following facts:

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1.

Pursuant to the October 13, 2011 Case Management Order filed in this case, the last

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day to disclose expert witnesses is December 7, 2012; the last day to disclose rebuttal expert

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witnesses is December 17, 2012; and the last day for expert discovery, including expert depositions,

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is January 1, 2013.

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2.

On October 31, 2012, defendants filed a Motion for Summary Judgment or, in the

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Alternative, Partial Summary Judgment. The Motion was originally set for hearing on December

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13, 2012, but the Court continued the hearing to December 20, 2012.

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STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES FOR
EXPERT DISCLOSURES AND EXPERT DISCOVERY

Case No. 11-CV-1329 MEJ

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3.

The parties would like to continue the deadlines for expert disclosures and expert

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discovery to dates after this Court will have ruled on the Motion, so the expense of expert discovery

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can be avoided if the Motion is granted. An extension of the expert disclosure and discovery dates

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will not affect any of the other pretrial dates scheduled by the Court's October 13, 2011 Case

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Management Order.

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IT IS HEREBY STIPULATED by and between the parties, through their attorneys of record,

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that the dates for expert disclosures and the deadline for expert discovery shall be continued as

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follows:

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4.

The parties shall disclose expert witnesses by January 15, 2013;

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5.

The parties shall disclose rebuttal expert witnesses by January 25, 2013;

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6.

Expert discovery shall be completed by February 15, 2013; and

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7.

The discovery cutoff date of January 1, 2013 shall remain in effect with respect to all

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non-expert discovery.

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DATED: December 5, 2012

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EVAN LIVINGSTONE
Attorney for Plaintiff JULIO PALOMINO

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By: /s/ Evan Livingstone
Evan Livingstone

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DATED: December 5, 2012

SPAULDING McCULLOUGH & TANSIL LLP
Attorneys for Defendants COUNTY OF SONOMA,
SHERIFF BILL COGBILL and JOSHUA
CLAASSEN (incorrectly sued herein as DEPUTY
"CLAUSEN")

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By: /s/Terry S. Sterling
Terry S. Sterling

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STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES FOR
EXPERT DISCLOSURES AND EXPERT DISCOVERY

Case No. 11-CV-1329 MEJ

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[PROPOSED] ORDER
IT IS SO ORDERED

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DATED: December 6

, 2012
CHIEF UNITED STATES MAGISTRATE JUDGE
Maria-Elena James

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STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES FOR
EXPERT DISCLOSURES AND EXPERT DISCOVERY

Case No. 11-CV-1329 MEJ