Brock v. County of Napa

Filing 21

STIPULATION AND ORDER re 20 STIPULATION WITH PROPOSED ORDER filed by Gayle Brock, County of Napa. Signed by Judge ARMSTRONG on 1/31/12. (lrc, COURT STAFF) (Filed on 1/31/2012)

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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]

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Attorneys for Defendant
COUNTY OF NAPA

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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GAYLE BROCK,
Plaintiff,

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Case No.: CV 11-0257 SBA
STIPULATION EXTENDING DEADLINES
FOR EXPERT DISCLOSURES, EXPERT
DISCOVERY AND DEPOSITION OF
OFFICER SKILLINGS; ORDER

vs.
COUNTY OF NAPA and DOES 1 through 50,
inclusive,

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Defendants.
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Plaintiff GAYLE BROCK and defendant COUNTY OF NAPA hereby enter into this

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Stipulation Extending Deadlines For Expert Disclosures, Expert Discovery And Deposition Of

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Officer Skillings with reference to the following facts:

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A number of critical depositions have been taken in the last two weeks, and others are

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scheduled to be taken on January 27, 30 and 31, 2012. January 31, 2012 is currently both the cutoff

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date for non-expert discovery and the deadline for initial expert disclosures. Transcripts of the recent

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and upcoming depositions will not be completed in time for the parties’ experts to review the

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deponents’ testimony prior to the current deadline for expert disclosures.

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The parties have not been able to schedule the deposition of one percipient witness,

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Correctional Officer Kevin Skillings, prior January 31, 2012. Scheduling difficulties have arisen as a

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result of Officer Skillings’ recent assignment to work the graveyard shift at the Napa County Jail, and

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as a result of the attorneys’ calendars.

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STIPULATION EXTENDING DEADLINES FOR EXPERT DISCLOSURES, EXPERT
DISCOVERY AND DEPOSITION OF OFFICER SKILLINGS; [PROPOSED] ORDER

Case No. CV 11-0257 SBA

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A continuance of the dates for expert disclosures and the expert discovery deadline is needed

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to allow time for the transcripts of all recent and upcoming depositions to be prepared and made

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available to the parties’ experts for review before those experts and their opinions are disclosed. In

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addition, a continuance of the non-expert discovery cutoff date is needed for the limited purpose of

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scheduling the deposition of Officer Skillings. No other continuance of the deadline for non-expert

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discovery is sought by this Stipulation.

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IT IS HEREBY STIPULATED by and between plaintiff GAYLE BROCK and defendant

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COUNTY OF NAPA, through their attorneys of record, that the dates for expert disclosures, the

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expert discovery deadline and the non-expert discovery cutoff date shall be continued as follows:

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1.

The parties shall designate any experts by March 1, 2012;

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2.

The parties shall disclose any rebuttal experts by March 15, 2012;

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3.

Expert discovery shall be completed by April 10, 2012; and

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4.

The cutoff date for non-expert discovery shall be continued through February 17, 2012

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for the limited purpose of scheduling the deposition of Officer Kevin Skillings. With respect to all

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other non-expert discovery, the discovery cutoff date of January 31, 2012 shall remain in effect.

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DATED: January 27, 2012

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SPAULDING McCULLOUGH & TANSIL LLP
Attorneys for Defendant
COUNTY OF NAPA

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By:

/s/ Terry S. Sterling
Terry S. Sterling

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DATED: January 27, 2012

LAW OFFICE OF JESSE S. TURNER
Attorneys for Plaintiff GAYLE BROCK

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By:
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/s/ Jesse S. Turner
Jesse S. Turner, Esq.

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STIPULATION EXTENDING DEADLINES FOR EXPERT DISCLOSURES, EXPERT
DISCOVERY AND DEPOSITION OF OFFICER SKILLINGS; [PROPOSED] ORDER

Case No. CV 11-0257 SBA

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ORDER
IT IS SO ORDERED.

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DATED: 1/31/12
UNITED STATES DISTRICT COURT JUDGE

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STIPULATION EXTENDING DEADLINES FOR EXPERT DISCLOSURES, EXPERT
DISCOVERY AND DEPOSITION OF OFFICER SKILLINGS; [PROPOSED] ORDER

Case No. CV 11-0257 SBA