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)

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Allison V. Saunders, Bar No. 220010
[e-mail]
Lauren T. Williams, Bar No. 266264
[e-mail]
FORD & HARRISON LLP
350 South Grand Avenue, Suite 2300
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: 213-237-2401
Attorneys for Defendants
NORTH COUNTY FIRE PROTECTION
DISTRICT OF MONTEREY COUNTY and
CHRIS ORMAN
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JONATHAN RUSKELL,

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Plaintiff,

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v.

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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,

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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.

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Plaintiff Jonathan Ruskell (“Plaintiff”) and Defendants North County Fire

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Protection District of Monterey County and Chris Orman (“Defendants”), by and

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through their attorneys of record (collectively “Parties”), submit this Joint

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Stipulation and Order regarding proposed discovery and pre-trial cut-off dates per

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this Court’s January 21, 2016 order.

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WHEREAS, on January 21, 2016 this Court set the trial date, pre-trial

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conference, last day to commence mediation, and reserved a hearing date for

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Motion for Summary Judgement; and

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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

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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:

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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

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Expert Disclosure (Sur
Rebuttal)

7/28/2017

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Expert Discovery Cut-Off

8/11/2017

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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

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Final Pretrial Conference*

1/11/2018 at 1:30 P.M.

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Trial – (5 days)*

2/5/2018 at 9:00 A.M.

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*These dates have been set pursuant to the Court’s Case Management Order
entered 1/21/2016.

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F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

Case No.: 15-cv-03540-BLF

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SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES

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Dated: February 18, 2016

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Respectfully submitted,
FORD & HARRISON LLP

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By: /Allison V. Saunders/
Allison V. Saunders
Lauren T. Williams
Attorneys for Defendants

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NORTH COUNTY FIRE PROTECTION
DISTRICT OF MONTEREY COUNTY
and CHRIS ORMAN

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Dated: February 18, 2016

ADAMS, FERRONE AND FERRONE APC

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By: /Samantha M. Swanson/
Samantha M. Swanson
Attorneys for Plaintiff

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JONATHAN RUSKELL

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F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

Case No.: 15-cv-03540-BLF

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SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES

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[PROPOSED] ORDER

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The Court having reviewed the Parties' Joint Stipulation and [Proposed]

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Order regarding proposed discovery and pre-trial cut-off dates, ORDERS that the

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following discovery and pre-trial cut-off dates be established:

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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

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Expert Disclosure (Sur
Rebuttal)

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Expert Discovery Cut-Off

8/11/2017

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Hearing Date for Motions for
Summary Judgment*

10/19/2017 at 9:00 A.M.
9/7/2017

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Cut-Off for Hearings on NonDispositive Motions
(Discovery Motions)

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Final Pretrial Conference*

1/11/2018 at 1:30 P.M.

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Trial – (5 days)*

2/5/2018 at 9:00 A.M.

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*These dates have been set pursuant to the Court’s Case Management Order
entered 1/21/2016.

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IT IS SO ORDERED.
Dated: _____________, 2016

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____________________________________
Hon. Beth Labson Freeman
United States District Judge

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F ORD & H ARRISON
LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

Case No.: 15-cv-03540-BLF

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SECOND REVISED JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING PROPOSED
DISCOVERY AND PRE-TRIAL CUT-OFF DATES