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Jimenez v. County of Sacramento, 2:18-cv-00044-JAM-KJN. (2019)

Court: District Court, E.D. California Number: infdco20190612999 Visitors: 11
Filed: Jun. 10, 2019
Latest Update: Jun. 10, 2019
Summary: STIPULATION AND ORDER RE: EXTENSION OF EXPERT DISCOVERY DEADLINES JOHN A. MENDEZ , District Judge . IT IS HEREBY STIPULATED BY THE PARTIES TO ACTION NO. 2:18-CV-00044-JAM-KJN AS FOLLOWS: On January 9, 2018, plaintiff Luis Alberto Mendez Jimenez filed the instant action against defendants THE REGENTS OF THE UNIVERSITY OF CALIFORNIA; GREGORY SOKOLOV, M.D.; DANIELLE DASS, LCSW; CHARLENE WILLIAMS, N.P.; ANDREA JAVIST; COUNTY OF SACRAMENTO, DEPUTY TINLEY SEITZ, DEPUTY ALEXANDER EGENBERGER and
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STIPULATION AND ORDER RE: EXTENSION OF EXPERT DISCOVERY DEADLINES

IT IS HEREBY STIPULATED BY THE PARTIES TO ACTION NO. 2:18-CV-00044-JAM-KJN AS FOLLOWS:

On January 9, 2018, plaintiff Luis Alberto Mendez Jimenez filed the instant action against defendants THE REGENTS OF THE UNIVERSITY OF CALIFORNIA; GREGORY SOKOLOV, M.D.; DANIELLE DASS, LCSW; CHARLENE WILLIAMS, N.P.; ANDREA JAVIST; COUNTY OF SACRAMENTO, DEPUTY TINLEY SEITZ, DEPUTY ALEXANDER EGENBERGER and DEPUTY JORDAN LEE (hereafter, collectively referred to as "defendants");

On June 14, 2018, the court filed its Status (Pretrial Scheduling) Order setting forth all the operative dates governing scheduling of events in this case. In its order, the court ordered expert disclosures under Federal Rule of Civil Procedure 26(a)(2) to take place by June 28, 2019. Supplemental disclosures and disclosure of rebuttal experts under Federal Rule of Civil Procedure 26(a)(2)(c) were to be made by July 12, 2019. The court further ordered that all discovery, including all depositions, be completed by August 30, 2019; and

The parties to this action have been working diligently to complete discovery but it has come to light that it will be difficult, if not impossible, to complete (1) an independent medical examination ("IME") of plaintiff LUIS ALBERTO MENDEZ JIMENEZ, (2) the disclosure of expert reports, and (3) the depositions of experts by the above dates.

Given the foregoing, the parties have met and conferred and hereby stipulate to an extension of the expert discovery deadlines as follows:

1. Extend expert disclosure from June 28, 2019 to July 19, 2019; and

2. Extend supplemental expert and rebuttal expert disclosure date from July 12, 2019 to August 2, 2019.

All other discovery deadlines, including the current August 30, 2019 discovery cutoff date, the law and motion dates, and the February 3, 2020 trial date shall remain in effect.

It is here by stipulated by and between the parties through their respective counsel of record that the expert discovery deadlines may be extended as set forth above, subject to approval of the court.

DATED: June 7, 2019 WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP BIANCA S. SAMUEL NEAL C.LUTTERMAN Attorneys for Defendants THE REGENTS OF THE UNIVERSITY OF CALIFORNIA; GREGORY SOKOLOV, M.D.; DANIELLE DASS, LCSW; CHARLENE WILLIAMS, N.P.; and ANDREA JAVIST DATED: June 7, 2019 LAW OFFICES OF MILES, SEARS & EANNI A PROFESSIONAL CORPORATION DOUGLAS L. GORDON MEGAN K. CROSBIE Attorneys for Plaintiff Luis Alberto Mendez Jimenez DATED: June 7, 2019 LONGYEAR, O'DEA & LAVRA, LLP VAN LONGYEAR NICOLE M. CAHILL Attorneys for Defendants COUNTY OF SACRAMENTO, DEPUTY TINLEY SEITZ, DEPUTY ALEXANDER EGENBERGER and DEPUTY JORDAN LEE

ATTESTATION REGARDING SIGNATURES

I, Bianca S. Samuel, hereby attest that all other signatories listed, and on whose behalf the filing is submitted, concur in the filings content and have authorize the filing.

Date: June 7, 2019 Bianca S. Samuel

ORDER OF RE: EXTENSION OF EXPERT DISCOVERY DEADLINES

Based upon the foregoing Stipulation of the parties and good cause appearing, it is hereby ordered that:

1. Expert disclosures are now due on July 19, 2019;

2. Supplemental expert and rebuttal expert disclosures are now due on August 2, 2019;

3. All other discovery deadlines and all law and motion and trial dates established previously by the court's pretrial Scheduling Order dated June 14, 2019 shall remain in effect.

Source:  Leagle

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