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STIPULATION AND [PROPOSED] ORDER TO AMEND CASE MANAGEMENT AND PRETRIAL ORDER

4:17-cv-00911-PJH

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KATHARINE L. ELLIOTT, County Counsel SBN 135253

BRINA A. BLANTON, Deputy, SBN 260829

County of Mendocino – Administration Center

501 Low Gap Road, Room 1030

Ukiah, CA 95482

Telephone: (707) 234-6885

Facsimile: (707) 463-4592 

blantonb@mendocinocounty.org

Attorneys for Defendants

COUNTY OF MENDOCINO, THOMAS D. ALLMAN, LORRIE KNAPP, and MICHAEL 

GRANT

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

MARGARET WARD, in her personal capacity, 

and as executor of the estate of Earl Ward, 

Deceased, KEVIN WARD and INA WARD, 

surviving heir of JEFF WARD

Plaintiffs,

V.

COUNTY OF MENDOCINO; SHERIFF 

THOMAS D. ALLMAN, individually and in 

his official capacity as Sheriff of the COUNTY 

OF MENDOCINO; LORRIE KNAPP;

MICHAEL GRANT; CALIFORNIA 

FORENSIC MEDICAL GROUP, INC.; DR. 

MICHAEL MEDVIN; DR. MARVIN 

TROTTER; KATHY LOUISE GOODMAN; 

KINDRED HEALTHCARE OPERATING, 

INC.; and DOES 1 through 100, inclusive.

Defendants.

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Case No. 4:17-cv-00911-PJH

STIPULATION AND [PROPOSED] 

ORDER TO AMEND CASE 

MANAGEMENT AND PRETRIAL 

ORDER

WHEREAS the plaintiffs and defendants in this action have participated in a settlement 

scheduling conference under the guidance and recommendation of the assigned settlement 

AS MODIFIED BY THE COURT
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STIPULATION AND [PROPOSED] ORDER TO AMEND CASE MANAGEMENT AND PRETRIAL ORDER

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judge in this matter, the Hon. Laurel Beeler, and 

WHEREAS the Case Management and Pretrial Order (Dkt. 31) was entered on June 19, 

2017, before plaintiffs filed their Third Amended Complaint (Dkt. 59) on February 1, 2018, to 

add two additional defendants, Kathy Louise Goodman as Doe Defendant 1 and Kindred 

Healthcare Operating, Inc. as Doe Defendant 2, and

WHEREAS defendant Kindred Healthcare Operating, Inc. first appeared in this matter 

on March 7, 2018, and

WHEREAS defendant Kathy Louise Goodman first appeared in this matter on April 

18, 2018, and

WHEREAS a settlement conference had been set for August 15, 2018, and

WEHREAS one of the Plaintiffs was diagnosed with a serious medical condition and 

will not be able to attend the August 15, 2018 settlement conference, and

WHEREAS the parties are currently working to continue the settlement conference to a 

date when all parties can be present, and 

WHEREAS the non-expert discovery cutoff was reset to October 1, 2018, pursuant to 

the pretrial schedule set forth in the court’s Case Management and Pretrial Order (Dkt. 85), and

WHEREAS all other deadlines originally set in this case remain and are as of the 

resetting of the non-expert discovery cutoff are incompatible with that date, and

WHEREAS the plaintiffs and defendants in this action are aware of the procedure for 

amending the court’s Case Management and Pretrial Order (Dkt. 31) and have concurrently 

filed a letter brief with the court, in accordance with said procedure, and

WHEREAS good cause exists for an order amending the court’s Case Management and 

Pretrial Order (Dkt. 31), as set forth above.

THE PARTIES HEREBY STIPULATE TO THE FOLLOWING PROPOSED CASE 

MANAGEMENT AND PRETRIAL ORDER:
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STIPULATION AND [PROPOSED] ORDER TO AMEND CASE MANAGEMENT AND PRETRIAL ORDER

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Deadline/Hearing Currently Due/Set Proposed Due/Set

Non-Expert Discovery Cut-off October 1, 2018 November 1, 2018

Disclosure of Experts August, 1, 2018 November 30, 2018

Rebuttal August 31, 2018 December 29, 2018

Dispositive Motions October 3, 2018 January 3, 2019

Expert Discovery Cut-Off November 11, 2018 January 11, 2019

Pretrial Conference January 10, 2019 August 15, 2019 

Trial February 4, 2019 September 9, 2019 

Dated: July 27, 2018 KATHARINE L. ELLIOTT

County Counsel

By: /s/

BRINA A. BLANTON, DEPUTY

Attorneys for Defendants

COUNTY OF MENDOCINO, THOMAS 

ALLMAN, LORRIE KNAPP, and MICHAEL 

GRANT

Dated: July 27, 2018 J SUPPLE LAW

A Professional Corporation 

By: /s/

JOHN L. SUPPLE

JODIE C. FEUSNER

MATTHEW SCHROEDER 

Attorneys for Defendants

KATHY LOUISE GOODMAN and 

KINDRED HEALTHCARE OPERATING, 

INC. 

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STIPULATION AND [PROPOSED] ORDER TO AMEND CASE MANAGEMENT AND PRETRIAL ORDER

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Dated: July 27, 2018 BRENT & FIOL, LLP

By: /s/

DAVID L. FIOL

Attorneys for Plaintiffs

Dated: July 27, 2018 THE LAW OFFICES OF JEROME M. 

VARANINI

By: /s/

JEROME M. VARANINI

Attorneys for Defendants

CALIFORNIA FORENSIC MEDICAL 

GROUP, INC. and DR. MICHAEL MEDVIN

Dated: July 27, 2018 SCHUERING, ZIMMERMAN & DOYLE

By: /s/

THEODORE D. POPPINGA

Attorneys for Defendant

DR. MARVIN TROTTER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: ________________________

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HON. PHYLLIS J. HAMILTON

United States District Judge

July 30, 2018 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

IT IS SO ORDERED

Judge Phyllis J. Hamilton