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Julio Palomino v. California Forensic Medical Group

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


December 6, 2012

JULIO PALOMINO, PLAINTIFF,
v.
CALIFORNIA FORENSIC MEDICAL GROUP,
DR. TAYLOR FITHIAN, COUNTY OF SONOMA,
SHERIFF BILL COGBILL, DEPUTY "CLAUSEN" AND DOES 1-10,
DEFENDANTS.

The opinion of the court was delivered by: Maria-Elena James Chief United States Magistrate Judge

STIPULATION AND [PROPOSED] ORDER EXTENDING DEADLINES FOR EXPERT DISCLOSURES AND EXPERT DISCOVERY

Plaintiff JULIO PALOMINO and defendants COUNTY OF SONOMA, SHERIFF BILL COGBILL and JOSHUA CLAASSEN (incorrectly sued herein as DEPUTY "CLAUSEN") hereby 19 enter into this Stipulation Extending Deadlines For Expert Disclosures and Expert Discovery with 20 reference to the following facts: 21

1. Pursuant to the October 13, 2011 Case Management Order filed in this case, the last 2 day to disclose expert witnesses is December 7, 2012; the last day to disclose rebuttal expert 23 witnesses is December 17, 2012; and the last day for expert discovery, including expert depositions, 24 is January 1, 2013.

2. On October 31, 2012, defendants filed a Motion for Summary Judgment or, in the Alternative, Partial Summary Judgment. The Motion was originally set for hearing on December 13, 2012, but the Court continued the hearing to December 20, 2012.

3. The parties would like to continue the deadlines for expert disclosures and expert discovery to dates after this Court will have ruled on the Motion, so the expense of expert discovery 3 can be avoided if the Motion is granted. An extension of the expert disclosure and discovery dates 4 will not affect any of the other pretrial dates scheduled by the Court's October 13, 2011 Case 5 Management Order. 6

IT IS HEREBY STIPULATED by and between the parties, through their attorneys of record, that the dates for expert disclosures and the deadline for expert discovery shall be continued as 8 follows: 9

4. The parties shall disclose expert witnesses by January 15, 2013;

5. The parties shall disclose rebuttal expert witnesses by January 25, 2013;

6. Expert discovery shall be completed by February 15, 2013; and

7. The discovery cutoff date of January 1, 2013 shall remain in effect with respect to all non-expert discovery. 14

DATED: December 5, 2012 EVAN LIVINGSTONE Attorney for Plaintiff JULIO PALOMINO 17 By: /s/ Evan Livingstone Evan Livingstone 18 DATED: December 5, 2012 SPAULDING McCULLOUGH & TANSIL LLP 19 Attorneys for Defendants COUNTY OF SONOMA, SHERIFF BILL COGBILL and JOSHUA CLAASSEN (incorrectly sued herein as DEPUTY 20 "CLAUSEN")

By: /s/Terry S. Sterling

Terry S. Sterling

[PROPOSED] ORDER

IT IS SO ORDERED

20121206

© 1992-2012 VersusLaw Inc.



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