Carol A. Wieckowski, Esq. (SBN 95586) Cathleen J. Fralick, Esq. (SBN 146378) EVANS, WIECKOWSKI & WARD, LLP 745 University Avenue Sacramento, CA 95825 Telephone: (916)923-1600 Facsimile: (916)923-1616 Attorneys for Defendants TRACI LEE, LISA TRAVIS, SCOTT FERA AND CHRISTOPHE GUILLON
PUBLIC ENTITY EMPLOYEES-FILING FEES WAIVED
STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER Action filed: 3/4/2010 Third Amended Complaint: 12/16/11
It is hereby stipulated and agreed by all parties, Defendants COUNTY OF SACRAMENTO, JEANINE LOPEZ, FERMINE PEREZ, JENNIFER CULLIVAN, BRYAN JONES, ROBIN ROGERS, KEEVA PIERCE, VERONICA CARILLO, STEPHANIE LYNCH, LYYN FRANK, CLAUDIA SOLLA, LAURA COULTHARD, EVA SCHRAGE, KIM PEARSON, MELINDA LAKE, FRED DeMARTIN, JONI EDISON, WENDY CHRISTIAN, PATTI GILBERT-DRIGGS, DEPARTMENT OF HEALTH AND HUMAN SERVICES, CHILD PROTECTIVE SERVICES, and Defendants TRACI LEE, LISA TRAVIS, SCOTT FERA AND CHRISTOPHE GUILLON, and Plaintiffs EDWARD OLVERA, CARLA DE ROSE, INDIVIDUALLY AND AS GUARDIAN AD LITEM FOR AND-O, CHDD-O, COD-O, SD-O, AGD-O, GD-O, RD-O, MINOR CHILDREN, SUSAN MORRISON, KELLY MEIS, that the ORDER OF THE COURT REGARDING MODIFICATION OF SCHEDULING ORDER be modified as follows so that everything gets continued 90 days:
1. Non-expert discovery set for May 14, 2012 be continued to August 14, 2012;
2. Plaintiff's Expert Disclosure date set for April 11, 2012 be continued to July 11, 2012;
3. Defendants Expert Disclosure date set for May 7, 2012 be continued to August 7, 2012;
4. Rebuttal Expert Disclosure set for June 1, 2012 be continued to September 4, 2012;
5. Expert Discovery Cut Off set for July 23, 2012 be continued to October 23, 2012;
6. Dispositive Motion Deadline set for September 11, 2012 be continued to December 11, 2012;
7. Pretrial Conference scheduled for November 26, 2012 at 2:00 p.m. be continued to February 19, 2013 at 2:00 p.m.
8. Jury Trial scheduled for January 23, 2013 at 9:00 a.m. be continued to April 23, 2013 at 9:00 a.m.
There is good cause for this continuance pursuant to Fed. R. Civ. P. 16(b)(4) in that plaintiffs filed a motion to amend the second amended complaint to add thirteen (13) additional defendants which was granted on December 5, 2011. Some of these new defendants SACRAMENTO DEPUTY COUNTY COUNSEL TRACI LEE, LISA TRAVIS, SCOTT FERA AND CHRISTOPHE GUILLON were assigned new counsel Carol A. Wieckowski of EVANS, WIECKOWSKI, AND WARD, LLP, to represent them in this case. Ms. Wieckowski is diligently seeking this modification. She was just assigned as counsel on March 28, 2012 and needs more time to complete non expert discovery and to obtain experts. She just received a copy of the voluminous file on April 3, 2012 and it is extensive in terms of discovery (24 depositions have been taken to date) and needs more time to determine what discovery is to be completed on behalf of her clients and retain experts. There also has been substantial written discovery requests and numerous documents to review. All parties have agreed to this continuance.