Opinion
Case No. 1:11-CV-00604-AWI GSA
01-10-2013
JINNY LYNN PEARCE, Plaintiff, v. COUNTY OF KERN, ANTHONY MICHAEL LAVIS, and DOES 1 to 100, inclusive Defendants.
THERESA A. GOLDNER, COUNTY COUNSEL Mark L. Nations, Chief Deputy Attorneys for Defendant County of Kern ROBINSON KELLAR Oliver U. Robinson Attorney for Defendant Anthony Lavis RODRIGUEZ AND ASSOCIATES Martha Rossiter Attorneys for Plaintiff Jinny Lynn Pearce
THERESA A. GOLDNER, COUNTY COUNSEL
COUNTY OF KERN, STATE OF CALIFORNIA
By: Mark L. Nations, Chief Deputy (Bar # 101838)
County Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, California 93301
Telephone: (661) 868-3800
Fax: (661) 868-3805
Attorneys for Defendant
COUNTY OF KERN
SECOND STIPULATION TO
CONTINUE EXPERT DISCOVERY
CUTOFF
The parties herein, by and through their respective counsel, hereby agree and stipulate as follows:
1. On November 26, 2012, Defendant County of Kern served a Notice of Taking Deposition of Plaintiff's Expert setting the deposition for December 10, 2012.
2. Plaintiff's expert witness was unavailable on December 10, 2012.
3. Due to the calendar conflicts of counsel, the expert's availability, and the holidays the parties were unable to coordinate another date for the deposition prior to the expert discovery cutoff of December 28, 2012.
4. On December 10, 2012, the parties stipulated to extend expert discovery cutoff to January 10, 2012, for the sole purpose of taking the deposition of Plaintiff's expert.
5. On January 4, 2012, Plaintiff's attorney informed Defendants that the expert was unavailable for deposition on January 10, 2013, because he has been called to testify in a court proceeding.
6. The parties have now agreed to take the deposition of Plaintiff's expert on January 22, 2013.
THERFORE THE PARTIES AGREE AND STIPULATE to continue the expert discovery cutoff date of December 28, 2012, previously extended to January 10, 2013, to January 22, 2013, for the sole purposes of deposing Plaintiff's expert.
The parties herein agree this stipulation may be signed in counterpart.
THERESA A. GOLDNER, COUNTY COUNSEL
By:_________________
Mark L. Nations, Chief Deputy
Attorneys for Defendant County of Kern
ROBINSON KELLAR
By: _________________
Oliver U. Robinson
Attorney for Defendant Anthony Lavis
RODRIGUEZ AND ASSOCIATES
By: _________________
Martha Rossiter
Attorneys for Plaintiff Jinny Lynn Pearce
ORDER
The Court, having read the foregoing Stipulation and good cause appearing therefore, HEREBY ORDERS that the Expert Discovery Cutoff in this matter be continued to January 22, 2013, for the sole purpose of deposing Plaintiff's expert witness. IT IS SO ORDERED.
Gary S. Austin
UNITED STATES MAGISTRATE JUDGE