Filed: Jan. 06, 2020
Latest Update: Jan. 06, 2020
Summary: STIPULATION AND ORDER MODIFYING CASE SCHEDULE MORRISON C. ENGLAND, JR. , District Judge . Whereas, the parties in the above action are engaging in discovery of merits issues; Whereas, Plaintiff's original counsel, Gregory P. O'Dea, has left the firm of Longyear, O'Dea & Lavra, LLP, and the firm of Longyear & Lavra, LLP is unable to handle the action of County of Sacramento. Whereas, County of Sacramento has arranged for substitution of its counsel, substituting Farmer, Smith & Lane, LLP,
Summary: STIPULATION AND ORDER MODIFYING CASE SCHEDULE MORRISON C. ENGLAND, JR. , District Judge . Whereas, the parties in the above action are engaging in discovery of merits issues; Whereas, Plaintiff's original counsel, Gregory P. O'Dea, has left the firm of Longyear, O'Dea & Lavra, LLP, and the firm of Longyear & Lavra, LLP is unable to handle the action of County of Sacramento. Whereas, County of Sacramento has arranged for substitution of its counsel, substituting Farmer, Smith & Lane, LLP, ..
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STIPULATION AND ORDER MODIFYING CASE SCHEDULE
MORRISON C. ENGLAND, JR., District Judge.
Whereas, the parties in the above action are engaging in discovery of merits issues;
Whereas, Plaintiff's original counsel, Gregory P. O'Dea, has left the firm of Longyear, O'Dea & Lavra, LLP, and the firm of Longyear & Lavra, LLP is unable to handle the action of County of Sacramento.
Whereas, County of Sacramento has arranged for substitution of its counsel, substituting Farmer, Smith & Lane, LLP, resulting in the need for new Plaintiff's counsel to become familiar with the facts and circumstances of the action and in order to respond to discovery and prepare for trial;
Whereas, the parties agree that an extension of the deadlines in the Court's Initial Scheduling Order is necessary and appropriate to permit completion of approprirate discovery prior to the disclosure of expert witnesses, dispositive motions and pretrial proceedings;
IT IS HEREBY STIPULATED by the parties, through their counsel of record, that:
1. The current deadlines in the Scheduling Order dated February 11, 2019, shall be extended as follows:
Discovery to and including April 1, 2020;
Disclosure of expert witnesses and reports on or before May 29, 2020;
Completion of Expert Discovery on or before July 24, 2020; and
Filing of Dispositive Motions on or before September 25, 2020.
Except as modified, the prior Scheduling Order remain unchanged.
DATED: December 13, 2019 SELMAN BREITMAN LLP
By: /s/James R. Tenero
JAMES R. TENERO
Attorneys for Defendant
Everest National Insurance Company
DATED: December 13, 2019 SELMAN BREITMAN LLP
By: /s/Craig E. Farmer
Craig E. Farmer
Attorneys for Plaintiff
County of Sacramento
SIGNATURE ATTESTATION
I, James R. Tenero, am the ECF user whose identification and password are being used to file this Stipulation extending time to respond to written discovery. In compliance with Local Rules, I hereby attest that the party signatories hereto concur in this filing.
/s/James R. Tenero
JAMES R. TENERO
ORDER
Pursuant to Stipulation, and good cause appearing, IT IS HEREBY ORDERED that the current deadlines in the Scheduling Order dated February 11, 2019, shall be extended as stated above.
IT IS SO ORDERED.
