Gregory G. Spaulding, Esq. (SBN 106606) Terry S. Sterling, Esq. (SBN 106379) 2 SPAULDING McCULLOUGH & TANSIL LLP 90 South E Street, Suite 200 3 P.O. Box 1867 Santa Rosa, CA 95402 4 Telephone: (707) 524-1900 Facsimile: (707) 524-1906 5 Attorneys for Defendant 6 COUNTY OF NAPA 7 8
STIPULATION EXTENDING DEADLINES FOR EXPERT DISCLOSURES, EXPERT DISCOVERY AND DEPOSITION OF ORDER
Plaintiff GAYLE BROCK and defendant COUNTY OF NAPA hereby enter into this Stipulation Extending Deadlines For Expert Disclosures, Expert Discovery And Deposition Of 18 Officer Skillings with reference to the following facts: 19
A number of critical depositions have been taken in the last two weeks, and others are 20 scheduled to be taken on January 27, 30 and 31, 2012. January 31, 2012 is currently both the cutoff 21 date for non-expert discovery and the deadline for initial expert disclosures. Transcripts of the recent 22 and upcoming depositions will not be completed in time for the parties' experts to review the 23 deponents' testimony prior to the current deadline for expert disclosures. 24
The parties have not been able to schedule the deposition of one percipient witness, Correctional Officer Kevin Skillings, prior January 31, 2012. Scheduling difficulties have arisen as a 26 result of Officer Skillings' recent assignment to work the graveyard shift at the Napa County Jail, and 27 as a result of the attorneys' calendars.
A continuance of the dates for expert disclosures and the expert discovery deadline is needed to allow time for the transcripts of all recent and upcoming depositions to be prepared and made 3 available to the parties' experts for review before those experts and their opinions are disclosed. In 4 addition, a continuance of the non-expert discovery cutoff date is needed for the limited purpose of 5 scheduling the deposition of Officer Skillings. No other continuance of the deadline for non-expert 6 discovery is sought by this Stipulation. 7
IT IS HEREBY STIPULATED by and between plaintiff GAYLE BROCK and defendant
COUNTY OF NAPA, through their attorneys of record, that the dates for expert disclosures, the 9 expert discovery deadline and the non-expert discovery cutoff date shall be continued as follows: 10
1. The parties shall designate any experts by March 1, 2012;
2. The parties shall disclose any rebuttal experts by March 15, 2012;
3. Expert discovery shall be completed by April 10, 2012; and
4. The cutoff date for non-expert discovery shall be continued through February 17, 2012 for the limited purpose of scheduling the deposition of Officer Kevin Skillings. With respect to all 15 other non-expert discovery, the discovery cutoff date of January 31, 2012 shall remain in effect. 16
UNITED STATES DISTRICT ...