Gaines v. Sacramento County Child Protective Services Agency

Full title: JACQUELINE GAINES, an individual and O.M., an individual and Minor, by and…

Court: United States District Court, Ninth Circuit, California, E.D. California, Sacramento Division

Date published: Sep 10, 2013

2:12-CV-01450-GEB-EFB (E.D. Cal. Sep. 10, 2013)

Opinion

JACQUELINE GAINES, an individual and O.M., an individual and Minor, by and through her guardian ad litem, Leroy H. Plaintiffs, v. SACRAMENTO COUNTY CHILD PROTECTIVE SERVICES AGENCY, an agency of the County of Sacramento, ANN EDWARDS, in her individual and professional capacities; SANDRA THOMPSON, in her individual professional capacities; SHAUNTE DERRICK, in her individual and professional capacities; SANTRICE DAVIS, in her individual and professional capacities; and DOES 1 through 25, INCLUSIVE Defendants. No. 2:12-CV-01450-GEB-EFB United States District Court, E.D. California, Sacramento Division. September 10, 2013

          STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME FOR CLOSE OF DISCOVERY, EXPERT WITNESS DISCLOSURES AND DISPOSITIVE MOTIONS LOCAL RULE 143

          GARIAND E. BURRELL, Jr., Senior District Judge.

         Pursuant to Local Rule 143, the Parties hereto, by and through their respective counsel, stipulate to extend the time for discovery, including expert witness disclosure and rebuttal expert witness disclosure, as well as the time for hearing any dispositive motion, in order to allow the parties time to explore mediation before incurring additional litigation costs.

         The parties jointly propose continuing the following deadlines as set forth below:

• Initial Disclosure of Expert Witnesses: current deadline of December 6, 2013. Proposed new deadline: January 24, 2014.

• Disclosure of Rebuttal Expert Witnesses: current deadline of January 6, 2014. Proposed new deadline: February 7, 2014.

• Discovery closes: current deadline of February 28, 2014. Proposed new deadline: March 28, 2014.

• Last day for hearing dispositive motions: current deadline of April 21, 2014. Proposed new deadline: May 5, 2014.

         WHEREAS, the parties wish to explore alternative dispute resolution through mediation before continuing with further discovery in an attempt to minimize litigation costs;

         WHEREAS, this request is not being made of the purposes of delay, or any other improper purpose;

         WHEREAS, continuing the deadlines for completing the disclosure of expert witnesses and other discovery, as well as the filing and hearing of dispositive motions will not prejudice any party or their counsel; and

         NOW, THEREFORE, IT IS HEREBY STIPULATED and agreed by Plaintiffs and Defendants, through their respective attorneys of record, that this Court continue the deadlines as set forth above.

         IT IS SO STIPULATED.

          ORDER

         Pursuant to stipulation, it is ordered that Initial Expert Witness Disclosure shall occur by January 24, 2014. Disclosure of Rebuttal Expert Witnesses shall occur by February 7, 2014. All discovery shall be completed by March 28, 2014. The last day for hearing dispositive motions shall be May 5, 2014.