Filed: May 08, 2019
Latest Update: May 08, 2019
Summary: STIPULATION AND ORDER AMENDING SCHEDULING ORDER (Doc. 95) SHEILA K. OBERTO , District Judge . The parties hereby stipulate and respectfully request that the Court consent to amending the Scheduling Order, Doc. No. 93, to extend the non-expert discovery deadline by 45 days 2 and the non-dispositive and dispositive motions dates by 14 days, for good cause, and in support state: 1. On December 13, 2018, the Court issued a scheduling order setting the following discovery deadlines: non-exper
Summary: STIPULATION AND ORDER AMENDING SCHEDULING ORDER (Doc. 95) SHEILA K. OBERTO , District Judge . The parties hereby stipulate and respectfully request that the Court consent to amending the Scheduling Order, Doc. No. 93, to extend the non-expert discovery deadline by 45 days 2 and the non-dispositive and dispositive motions dates by 14 days, for good cause, and in support state: 1. On December 13, 2018, the Court issued a scheduling order setting the following discovery deadlines: non-expert..
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STIPULATION AND ORDER AMENDING SCHEDULING ORDER
(Doc. 95)
SHEILA K. OBERTO, District Judge.
The parties hereby stipulate and respectfully request that the Court consent to amending the Scheduling Order, Doc. No. 93, to extend the non-expert discovery deadline by 45 days2 and the non-dispositive and dispositive motions dates by 14 days, for good cause, and in support state:
1. On December 13, 2018, the Court issued a scheduling order setting the following discovery deadlines: non-expert discovery complete by May 31, 2019; expert disclosures complete by June 7, 2019; rebuttal expert disclosures complete by June 14, 2019; and expert discovery complete by June 30, 2019. Doc. No. 93. The Court further set a deadline of July 31, 2019, for non-dispositive and dispositive motions. Id.
2. To date, the parties have engaged in active discovery, including production of hundreds of pages of documents and the deposition of eight witnesses. Furthermore, there are outstanding discovery disputes that the parties are actively attempting to resolve without the need for the Court's intervention.
3. The parties intend on conducting additional depositions of witnesses and the government intends on providing additional disclosures and production of documents to Plaintiffs, which is expected, in turn, to require additional discovery.
4. The parties agree that the additional time requested is necessary to allow the parties to complete discovery, and propose the following amended discovery schedule: non-expert discovery complete by July 15, 2019; expert disclosures due by July 19, 2019; rebuttal expert disclosures due by July 26, 2019; and expert discovery complete by August 9, 2019.
5. The parties also propose that non-dispositive and dispositive motion deadlines be extended 14 days to August 14, 2019, in order to not disrupt the dates set thereafter in the Scheduling Order. The parties do not wish to cause a change to the trial date.
6. This request is not made for any improper purpose or to create unnecessary delay, but rather to facilitate full and complete discovery in this case.
* * *
For the forgoing reasons, the parties hereby request that the Court modify its Scheduling Order as follows: non-expert discovery complete by July 15, 2019; expert disclosures due by July 19, 2019; rebuttal expert disclosures due by July 26, 2019; expert discovery complete by August 9, 2019; and non-dispositive and dispositive motions due by August 14, 2019.
Dated: May 8, 2019 Respectfully submitted,
/s/Bruce Leichty (with consent) JOSEPH H. HUNT
BRUCE LEICHTY Assistant Attorney General
Bruce Leichty, A Professional Corporation Civil Division
264 Clovis Avenue
Clovis, CA 93612 WILLIAM C. PEACHEY
Telephone: (559) 298-5900 Director
E-mail: leichty@sbcglobal.net District Court Section
Office of Immigration Litigation
Attorney for Plaintiffs
TIMOTHY M. BELSAN
Chief
/s/Anthony D. Bianco
ANTHONY D. BIANCO
Senior Litigation Counsel
Office of Immigration Litigation
Civil Division
United States Department of Justice
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Telephone: (202) 305-8014
E-mail: anthony.d.bianco@usdoj.gov
Attorneys for Defendants
ORDER
The Court, having considered the parties above Stipulation to Amend Scheduling Order to Extend Discovery (Doc. 95), and for good cause shown, hereby GRANTS an extension of discovery and other pretrial dates as follows:
Event Prior Date Continued Date
Non-Expert Discovery Completion May 31, 2019 July 15, 2019
Expert Disclosures June 7, 2019 July 19, 2019
Rebuttal Expert Disclosures June 14, 2019 July 26, 2019
Expert Discovery Completion June 30, 2019 August 9, 2019
Non-Dispositive Motion Filing July 31, 2019 August 14, 2019
Non-Dispositive Motion Hearing September 4, 2019 September 11, 2019
Dispositive Motion Filing July 31, 2019 August 14, 2019
Dispositive Motion Hearing September 5, 2019 September 19, 2019
All other dates in the Scheduling Order (Doc. 93), remain unchanged.
The Court also advises the parties that there is no more room in the schedule to further extend any other pretrial dates without moving the trial date. As such, this is the only stipulation to modify the Scheduling Order that the Court will entertain.
IT IS SO ORDERED.
