Opinion
Case No.: 1:09-CV-02204LJO-DLB
01-23-2012
AE, a minor, by and through his Guardian ad Litem, MARIBEL HERNANDEZ, Plaintiff, v. COUNTY OF TULARE, TULARE COUNTY HEALTH AND HUMAN SERVICES AGENCY, TULARE COUNTY CHILD WELFARE SERVICES, CELESTE ABARCA, PATRICIA NEGRETTE, YADIRA PORTILLO, PRUDENCE MORRIS, HELEN RUE, COURTNEY WAMPLER, CWA FELIX, HEIDI WILLIAMS, DR. SOTO, ADRIAN MARQUEZ, TIFFANY BREEN, LETICIA QUEZADA, MARIE FOCHA, MIRIAM SALLAM, and Does 1 to 100, inclusive, Defendants.
J. MIGUEL FLORES Esq. Attorneys for Plaintiff AE KATHLEEN BALES-LANGE Tulare County Counsel JUDY CHAPMAN, Deputy County Counsel BORTON PETRINI LLP GAIL S. BRAZE, Attorneys for Third-Party Defendant, Family Builders Foster Care, Inc. WEST & MIYAMOTO EUGENE F. WEST Attorneys for Cross-Defendant, Sandra Ceballos
DANIEL RODRIGUEZ, ESQ., SBN 096625
J. MIGUEL FLORES, ESQ., SBN 240535
RODRIGUEZ & ASSOCIATES
Attorneys for Claimant AE, a minor,
by and through his Guardian ad Litem,
MARIBEL HERNANDEZ
STIPULATION TO CONTINUE
DEADLINE FOR EXPERT
DISCLOSURE,
SUPPLEMENTAL DISCLOSURE
OF EXPERT AND CONTINUE
THE DEALINE FOR
COMPLETION OF EXPERT
DISCOVERY;
ORDER THEREON
Complaint filed: 12/17/2009
Trial Date: 10/23/2012
IT IS HEREBY STIPULATED by and between the parties hereto, through their respective counsel, that the deadline for the disclosure of expert witnesses scheduled for January 20, 2012, be continued to February 20, 2012, the supplemental disclosure of expert witnesses scheduled for February 10, 2012, be continued to March 12, 2012, and that the deadline to complete expert discovery also be continued from March 2, 2012 to April 2, 2012. The continuance is necessary in that the records for plaintiff AE which were subpoenaed from the Tulare County Health and Human Services Agency were yet to be received by the parties and only were recently ordered released by the Tulare County Superior Court on January 17, 2011. These records are a necessary part of plaintiff's records that need to be reviewed by experts for the parties. In addition, Defendants YADIRA PORTILLO, COURTNEY WAMPLER, CWA FELIX and SANDRA CEBALLOS have set an independent medical (psychological) evaluation of plaintiff AE for February 1, 2012. The results of that examination will also need to be reviewed by experts for the parties.
Rodriguez & Associates
By: _________________
J. MIGUEL FLORES Esq.
Attorneys for Plaintiff AE
KATHLEEN BALES-LANGE
Tulare County Counsel
By_________________
JUDY CHAPMAN,
Deputy County Counsel
IT IS SO ORDERED.
BORTON PETRINI LLP
By_________________
GAIL S. BRAZE, Attorneys for
Third-Party Defendant, Family
Builders Foster Care, Inc.
WEST & MIYAMOTO
By _________________
EUGENE F. WEST
Attorneys for Cross-Defendant,
Sandra Ceballos
Dennis L. Beck
UNITED STATES MAGISTRATE JUDGE