Figueroa v. Kern County

CourtDistrict Court, E.D. California
DecidedJanuary 10, 2025
Docket1:19-cv-00558
StatusUnknown

This text of Figueroa v. Kern County (Figueroa v. Kern County) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Figueroa v. Kern County, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 VICENTE BENAVIDES FIGUEROA, No. 1:19-cv-00558-KES-CDB 12 Plaintiff, 13 v. ORDER DENYING COUNTY OF KERN’S MOTION FOR RECONSIDERATION OF 14 KERN COUNTY, et al. DENIAL OF REQUEST TO EXTEND REBUTTAL EXPERT DISCLOSURE 15 Defendants. DEADLINE 16 Doc. 108 17 18 Plaintiff Vicente Benavides Figueroa (“Figueroa”) brought this civil rights and negligence 19 action against several defendants after the California Supreme Court vacated his criminal 20 conviction. Plaintiff alleges that due to defendants’ misconduct he served 25 years in prison for a 21 crime he did not commit. The parties jointly moved for an order extending certain case 22 management dates as plaintiff’s expert witness was unavailable to appear for deposition due to 23 unexpected medical reasons. Doc. 102. Defendant County of Kern (“County of Kern”) 24 separately moved, after the expiration of the rebuttal expert disclosure deadline, for a nunc pro 25 tunc extension of that disclosure deadline (Doc. 100), which Figueroa opposed (Doc. 105).1 The 26 assigned magistrate judge granted the parties’ joint motion, finding good cause to adopt the 27 1 County of Kern was erroneously named in the third amended complaint as “Kern 28 County.” Doc. 66. 1 proposed amendments to the scheduling order, but denied County of Kern’s separate motion to 2 extend the rebuttal expert disclosure deadline. Doc. 107. The magistrate judge found that County 3 of Kern’s request for relief was untimely and that the County failed to demonstrate diligence. 4 Doc. 107 at 3–4. Pursuant to Federal Rule of Civil Procedure 72(a), County of Kern moved for 5 reconsideration of the magistrate judge’s order as to the denial of the County’s request to extend 6 the rebuttal expert disclosure deadline. Doc. 108. For the reasons discussed below, the Court 7 denies the motion for reconsideration. 8 I. RELEVANT PROCEDURAL HISTORY 9 The first scheduling order in this case was issued on May 3, 2021. Doc. 59. It was 10 modified several times pursuant to the parties’ stipulations. Docs. 80, 83, 88, 91, 96. After the 11 fourth such stipulated request, the assigned magistrate judge modified the discovery schedule in 12 part, extending the date for non-expert discovery to permit the parties to complete limited 13 discovery. Doc. 91. The magistrate judge otherwise denied the stipulation, not finding good 14 cause to modify the remaining deadlines and warning the parties that further requests for 15 extension were strongly discouraged and would not be granted absent a showing of diligence and 16 good cause. Doc. 91 at 4. 17 One month later, County of Kern renewed an earlier request for an extension of time 18 relating to the transcription of belatedly discovered aged cassette tapes (Doc. 92), and Figueroa 19 and counsel for two other defendants joined in County of Kern’s application (Docs. 94, 95). 20 Finding good cause, the assigned magistrate judge granted the request and amended the 21 scheduling order.2 Doc. 96. Relevant here, the magistrate judge extended the deadline for 22 rebuttal expert disclosures by an additional 90 days: from July 12, 2023, to October 12, 2023. Id. 23 at 3. County of Kern failed to either identify rebuttal experts or move for an extension of the time 24 to do so by the October 12, 2023 deadline. 25 On October 31, 2023, after the rebuttal expert disclosure deadline had passed, County of 26

27 2 The new discovery deadlines were set as follows: Non-expert discovery: August 15, 2023; Expert disclosure: September 14, 2023; Rebuttal disclosure: October 12, 2023; and Expert 28 Discovery cut-off: October 31, 2023. 1 Kern moved for a nunc pro tunc extension of that deadline, asserting that it needed additional 2 time to identify a rebuttal expert. Doc. 100. Figueroa opposed County of Kern’s request. 3 Doc. 105. At the same time, the parties jointly moved for a brief extension of the expert 4 discovery deadline and certain motion and trial-related dates, on account of Figueroa’s expert 5 witness needing to undergo unexpected medical treatment. Doc. 102 at 6. The joint motion 6 requested that the proposed expert deadline apply only to those expert depositions that had been 7 timely noticed by October 31, 2023, which was the expert discovery deadline under the then- 8 existing scheduling order. Id. at 3, n.1. 9 Finding good cause as to the joint motion, the magistrate judge issued an order modifying 10 the scheduling order as requested. Doc. 107. The magistrate judge denied County of Kern’s 11 separate request to extend the rebuttal expert deadline, finding that the request was untimely and 12 that the County had failed to demonstrate diligence. Id. County of Kern timely objected to the 13 magistrate judge’s order. Doc. 108. The motion for reconsideration is fully briefed. Doc. 114 14 (“Opp’n”); Doc. 116 (“Reply”). 15 II. LEGAL STANDARD 16 A party may object to a magistrate judge's non-dispositive pretrial order within fourteen 17 (14) days after service of the order. See Fed. R. Civ. P. 72(a). The magistrate judge's order will 18 be upheld unless it is “clearly erroneous or contrary to law.” Id.; 28 U.S.C. § 636(b)(1)(A). The 19 objecting party has the burden of showing that the magistrate judge's ruling is clearly erroneous 20 or contrary to law. In re eBay Seller Antitrust Litig., No. C 07-1882 JF (RS), 2009 WL 3613511, 21 at *1 (N.D. Cal. Oct. 28, 2009). 22 A party seeking reconsideration must set forth facts or law of a strongly convincing nature 23 to induce the court to reverse a prior decision. Kern-Tulare Water Dist. v. City of Bakersfield, 24 634 F. Supp. 656, 665 (E.D. Cal. 1986), aff'd in part and rev'd in part on other grounds, 828 F.2d 25 514 (9th Cir. 1987)). “The ‘clearly erroneous’ standard applies to factual findings and 26 discretionary decisions made in connection with non-dispositive pretrial discovery matters.” 27 Comput. Econ., Inc. v. Gartner Grp., Inc., 50 F. Supp. 2d 980, 983 (S.D. Cal. 1999) (citing 28 Maisonville v. F2 Am., Inc., 902 F.2d 746, 748 (9th Cir. 1990)). Under the “clearly erroneous” 1 standard, “the district court can overturn the magistrate judge's ruling only if the district court is 2 left with the ‘definite and firm conviction that a mistake has been committed.’” E.E.O.C. v. 3 Peters’ Bakery, 301 F.R.D. 482, 484 (N.D. Cal. 2014) (quoting Burdick v. C.I.R., 979 F.2d 1369, 4 1370 (9th Cir. 1992)). “Thus, review under the ‘clearly erroneous’ standard is significantly 5 deferential.’” Concrete Pipe and Prods. of Cal., Inc. v. Constr. Laborers Pension Tr. For S. Cal., 6 508 U.S. 602, 623 (1993). 7 III. ANALYSIS 8 County of Kern has failed to show that the magistrate judge’s ruling was clearly erroneous 9 or contrary to law. Nor has it demonstrated its diligence sufficient to warrant a modification of 10 the rebuttal expert deadline. 11 “Rule 16(b)’s ‘good cause’ standard primarily considers the diligence of the party seeking 12 the amendment.” Johnson v. Mammoth Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992).

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Figueroa v. Kern County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/figueroa-v-kern-county-caed-2025.