Ruskell v. North County Fire Protection District of Monterey County et al
Filing
35
SECOND REVISED JOINT STIPULATION AND ORDER REGARDING PROPOSED DISCOVERY AND PRE-TRIAL CUTO-OFF DATES. Signed by Judge Beth Labson Freeman on 2/19/2016. (blflc1, COURT STAFF) (Filed on 2/19/2016)
1
2
3
4
5
6
7
8
Allison V. Saunders, Bar No. 220010
asaunders@fordharrison.com
Lauren T. Williams, Bar No. 266264
ltwilliams@fordharrison.com
FORD & HARRISON LLP
350 South Grand Avenue, Suite 2300
Los Angeles, CA 90071
Telephone: 213-237-2400
Facsimile: 213-237-2401
Attorneys for Defendants
NORTH COUNTY FIRE PROTECTION
DISTRICT OF MONTEREY COUNTY and
CHRIS ORMAN
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
11
JONATHAN RUSKELL,
12
Plaintiff,
13
v.
14
NORTH COUNTY FIRE
PROTECTION DISTRICT OF
MONTEREY COUNTY, a public
agency and/or municipal corporation;
CHRIS ORMAN, individually and
as Fire Chief; and DOES 1
THROUGH 10,
15
16
17
18
Case No. 15-cv-03540-BLF
Hon. Beth Labson Freeman
SECOND REVISED JOINT
STIPULATION AND [PROPOSED]
ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL
CUT-OFF DATES
Defendants.
19
20
Plaintiff Jonathan Ruskell (“Plaintiff”) and Defendants North County Fire
21
Protection District of Monterey County and Chris Orman (“Defendants”), by and
22
through their attorneys of record (collectively “Parties”), submit this Joint
23
Stipulation and Order regarding proposed discovery and pre-trial cut-off dates per
24
this Court’s January 21, 2016 order.
25
WHEREAS, on January 21, 2016 this Court set the trial date, pre-trial
26
conference, last day to commence mediation, and reserved a hearing date for
27
Motion for Summary Judgement; and
28
F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES
Case No.: 15-cv-03540-BLF
SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES
1
2
3
4
WHEREAS, the Court has ordered the Parties to provide additional proposed
discovery and trial related cut off dates.
NOW, THEREFORE, the Parties hereby agree and stipulate to the following
pre-trial and trial related dates and propose the same for this Court’s consideration:
5
6
7
PROPOSED SCHEDULE OF PRE-TRIAL AND TRIAL DATES
Matter
Proposed Date
Last Day to Amend Pleadings
or Add New Parties
2/29/2016
Fact Discovery Cut-Off
2/10/2017
Expert Disclosure (Initial)
6/9/2017
Expert Disclosure (Rebuttal)
7/14/2017
13
Expert Disclosure (Sur
Rebuttal)
7/28/2017
14
Expert Discovery Cut-Off
8/11/2017
15
Hearing Date for Motions for
Summary Judgment*
10/19/2017 at 9:00 A.M.
Cut-Off for Hearings on NonDispositive Motions
(Discovery Motions)
9/7/2017
8
9
10
11
12
16
17
18
19
Final Pretrial Conference*
1/11/2018 at 1:30 P.M.
20
Trial – (5 days)*
2/5/2018 at 9:00 A.M.
21
22
23
*These dates have been set pursuant to the Court’s Case Management Order
entered 1/21/2016.
24
25
26
27
28
F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES
Case No.: 15-cv-03540-BLF
-2-
SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES
1
Dated: February 18, 2016
2
Respectfully submitted,
FORD & HARRISON LLP
3
By: /Allison V. Saunders/
Allison V. Saunders
Lauren T. Williams
Attorneys for Defendants
4
5
6
NORTH COUNTY FIRE PROTECTION
DISTRICT OF MONTEREY COUNTY
and CHRIS ORMAN
7
8
9
Dated: February 18, 2016
ADAMS, FERRONE AND FERRONE APC
10
By: /Samantha M. Swanson/
Samantha M. Swanson
Attorneys for Plaintiff
11
12
13
JONATHAN RUSKELL
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES
Case No.: 15-cv-03540-BLF
-3-
SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES
1
[PROPOSED] ORDER
2
The Court having reviewed the Parties' Joint Stipulation and [Proposed]
3
Order regarding proposed discovery and pre-trial cut-off dates, ORDERS that the
4
following discovery and pre-trial cut-off dates be established:
5
6
Matter
Proposed Date
Last Day to Amend Pleadings
or Add New Parties
2/29/2016
Fact Discovery Cut-Off
2/10/2017
Expert Disclosure (Initial)
6/9/2017
Expert Disclosure (Rebuttal)
7/14/2017
7/28/2017
12
Expert Disclosure (Sur
Rebuttal)
13
Expert Discovery Cut-Off
8/11/2017
14
Hearing Date for Motions for
Summary Judgment*
10/19/2017 at 9:00 A.M.
9/7/2017
17
Cut-Off for Hearings on NonDispositive Motions
(Discovery Motions)
18
Final Pretrial Conference*
1/11/2018 at 1:30 P.M.
19
Trial – (5 days)*
2/5/2018 at 9:00 A.M.
7
8
9
10
11
15
16
20
21
*These dates have been set pursuant to the Court’s Case Management Order
entered 1/21/2016.
22
23
24
IT IS SO ORDERED.
Dated: _____________, 2016
25
26
____________________________________
Hon. Beth Labson Freeman
United States District Judge
27
28
F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES
Case No.: 15-cv-03540-BLF
-4-
SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?