Manzanillo v. Lewis

          Raymond J. Manzanillo, Plaintiff, represented by Aryeh Matthew Hersher, Seyfarth Shaw LLP, Francis J. Ortman, III, Seyfarth Shaw LLP, James Edward Barolo, Seyfarth Shaw LLP, Jason Michael Allen, Seyfarth Shaw LLP, Michael Anderson Wahlander, Seyfarth Shaw LLP & Selyn Hong, Seyfarth Shaw LLP.

          Gregory D. Lewis, Defendant, represented by Michael James Quinn, California State Attorney General's Office & Michael Lee Huggins, California Attorney General's Office.

          K. McGuyer, Defendant, represented by Michael James Quinn, California State Attorney General's Office & Michael Lee Huggins, California Attorney General's Office.

          T. A. Wood, Defendant, represented by Michael James Quinn, California State Attorney General's Office & Michael Lee Huggins, California Attorney General's Office.

          J. Hallock, Defendant, represented by Michael James Quinn, California State Attorney General's Office & Michael Lee Huggins, California Attorney General's Office.

          N. Brown, Defendant, represented by William Lee McCaslin, McNamara Law Firm & Peter Jon Hirsig, McNamara Law Firm.

          Matthew Cate, Defendant, represented by Michael James Quinn, California State Attorney General's Office & Michael Lee Huggins, California Attorney General's Office.

          California Office of the Inspector General, Interested Party, represented by James Casey Spurling, Office of the Inspector General.

          STIPULATION TO MODIFY SCHEDULING ORDER

          JON S. TIGAR, District Judge.

         Plaintiff Raymond Manzanillo ("Plaintiff") and Defendants N. Brown, Gregory D. Lewis, J. Hallock, K. McGuyer, Matthew Cate, and T.A. Wood ("Defendants") (collectively the "Parties") by and through their counsel hereby stipulate and jointly request the Court to extend certain deadlines in the Scheduling Order issued on May 18, 2016 (Dkt. No. 190).

         As noted in the Parties' previous request for leave to take certain depositions after the current fact discovery cut-off (Dkt. No. 196), the Parties intend to conduct a site visit of facilities at Pelican Bay State Prison and to depose Defendant Kurt McGuyer, Correctional Lieutenant John Diggle, Correctional Sergeant B. Grenert, and a representative of the California Department of Corrections and Rehabilitation ("CDCR") under Federal Rule of Civil Procedure 30(b)(6). Due to the Parties' schedules and the availability of the intended deponents, the Parties cannot complete those depositions or the site visit before the current fact discovery cut-off of August 5, 2016. Accordingly, the Parties request that the Court extend the fact discovery cut-off by approximately thirty (30) days, to September 2, 2016.

         Additionally, because the information obtained through those depositions and the site visit will likely be relevant for experts analyzing issues in this case, the Parties request that the Court extend the deadlines for expert disclosures, rebuttal disclosures, and expert discovery by approximately fourteen (14) days, to September 9, 30, and October 14, respectively.

         Accordingly, the Parties propose ...