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Terry Sandres, An Individual v. Corrections Corporation of America

March 23, 2011

TERRY SANDRES, AN INDIVIDUAL,
PLAINTIFF,
v.
CORRECTIONS CORPORATION OF AMERICA, A
MARYLAND CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: District Judge: Hon. Oliver W. Wanger

STIPULATION AND ORDER TO EXTEND: (1)THE DEADLINE TO COMPLETE EXPERT DISCOVERY; AND (2)THE DEADLINE TO FILE ALL NON-DISPOSITIVE PRE-TRIAL MOTIONS CONCERNING EXPERT DISCOVERY AND CORRESPONDING HEARING DATE

Magistrate: Hon. Jennifer L. Thurston Action

Filed: July 24, 2009 Trial Date: August 30, 2011

THE PARTIES TO THE ABOVE-CAPTIONED MATTER, by and through their respective attorneys of record, hereby enter into this stipulation to extend: (1) the deadline to complete all expert discovery; and (2) the deadline to file all non-dispositive pre-trial motions concerning expert discovery and the corresponding hearing date based on the following:

WHEREAS, the expert discovery cut-off date in this matter is currently April 1, 2011 (Declaration of Kathy H. Gao ("Gao Decl."), ¶ 2); and

WHEREAS, the parties have designated retained and non-retained experts in this matter (Gao Decl., ¶ 3); and

WHEREAS, plaintiff Terry Sandres ("Plaintiff") has designated Dr. Joseph Valentino as a non-retained expert (Gao Decl., ¶ 4); and

WHEREAS, Plaintiff has agreed not to de-designate Dr. Valentino as a non-retained expert (Gao Decl., ¶ 5); and

WHEREAS, counsel for the parties have agreed to private mediation with Steve Serratore in this matter on April 14, 2011 -- the earliest time that the parties and the mediator are all available for mediation (Gao Decl., ¶ 6); and

WHEREAS, Dr. Valentino's deposition was initially set for March 25, 2011, at a rate of $750.00 per hour (Gao Decl., ¶ 7); and

WHEREAS, the parties are currently working with counsel for Dr. Valentino on receiving Plaintiff's complete medical records prior to Dr. Valentino's deposition (Gao Decl., ¶ 8); and

WHEREAS, to complete expert discovery, the parties anticipate, among other things, Plaintiff submitting to an independent mental examination and taking depositions of each party's experts (Gao Decl., ¶ 9); and

WHEREAS, to avoid the anticipated costs of Plaintiff's mental examination and the depositions of both retained and non-retained experts, the parties believe that it is in their best interest, as well as in the preservation of their financial resources, that Plaintiff's independent mental examination and expert depositions occur after the parties' mediation on April 14, 2011 (Gao Decl., ¶ 10); and 2.

WHEREAS, the parties have met and conferred and believe it is in their best interest to extend: (1) the deadline to complete expert discovery to May 13, 2011; and (2) the deadline to file all non-dispositive pre-trial motions concerning expert discovery to May 20, 2011, and the date to ...


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