Filed: Jul. 28, 2017
Latest Update: Jul. 28, 2017
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE DISCOVERY MOTIONS AND EXCHANGE EXPERT REPORTS EDWARD J. DAVILA , District Judge . The parties to the above-entitled action have met and conferred regarding discovery and jointly request that the deadline to initiate discovery disputes with the court be extended to August 31, 2017. The parties are hopeful that all disputes can be resolved without involvement of the court, and more time is needed for County to gather and review the v
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE DISCOVERY MOTIONS AND EXCHANGE EXPERT REPORTS EDWARD J. DAVILA , District Judge . The parties to the above-entitled action have met and conferred regarding discovery and jointly request that the deadline to initiate discovery disputes with the court be extended to August 31, 2017. The parties are hopeful that all disputes can be resolved without involvement of the court, and more time is needed for County to gather and review the vo..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO FILE DISCOVERY MOTIONS AND EXCHANGE EXPERT REPORTS
EDWARD J. DAVILA, District Judge.
The parties to the above-entitled action have met and conferred regarding discovery and jointly request that the deadline to initiate discovery disputes with the court be extended to August 31, 2017. The parties are hopeful that all disputes can be resolved without involvement of the court, and more time is needed for County to gather and review the voluminous responsive documents. Among many other items, it has come to the parties' attention that there are thousands of pages of inmate grievance forms which have not been reviewed or produced, and it will require significant time and effort to review the documents to determine whether any of them are responsive records.
The parties are not requesting an extension for fact discovery cutoff. Plaintiff remains concerned that if and when documents are produced related to the current disputes, there may in fact be a need for further discovery. Plaintiff wishes to make clear there is no intended waiver of the right to request discovery be reopened after review of the discovery Plaintiff believes he is entitled to, some of which has been requested as far back as October of 2016 but only recently came to light as actually existing and in the possession of the County.
The parties further request an extension of the deadlines relating to expert discovery, so that outstanding responsive fact discovery can be produced by opposing counsel and provided to expert witness(es) prior to completing reports.
In addition, the parties request that the deadline for filing dispositive motions and the hearing date on such motions be extended as set forth below.
The requested dates are as follows:
August 31, 2017: Deadline to File Fact Discovery Motions
September 7, 2017: Deadline to Designate Opening Experts w/Reports
September 27, 2017: Deadline to Designate Rebuttal Experts w/Reports
October 18, 2017: Expert Discovery Cutoff
October 25, 2017: Deadline to File Expert Discovery Motion
November 1, 2017: Deadline to File Dispositive Motions
January 18, 2018 at 9:00 a.m.: Hearing on Dispositive Motions
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
I hereby attest that I have on file all holographic signatures corresponding to any signatures indicated by a conformed signature/S/ within this e-filed document.
[PROPOSED] ORDER
The deadlines and hearing date contained in the court's Pretrial Order (Doc 46) for the items noted below are extended as follows:
August 31, 2017: Deadline to File Fact Discovery Motions
September 7, 2017: Deadline to Designate Opening Experts w/Reports
September 27, 2017: Deadline to Designate Rebuttal Experts w/Reports
October 18, 2017: Expert Discovery Cutoff
October 25, 2017: Deadline to File Expert Discovery Motion
November 1, 2017: Deadline to File Dispositive Motions
January 18, 2018 at 9:00 a.m.: Hearing on Dispositive Motions
PURSUANT TO STIPULATION, IT IS SO ORDERED.
