Earp v. County of Tulare et al

Filing 20

JOINT STIPULATION OF THE PARTIES; ORDER signed by Magistrate Judge Michael J. Seng on 1/11/2012. (Yu, L)

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Dennis R. Thelen, SBN 83999
Kevin E. Thelen, SBN 252665
LE BEAU • THELEN , LLP
5001 East Commercenter Drive, Suite 300
Post Office Box 12092
Bakersfield, California 93389-2092
[phone]; Fax [phone]

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Attorneys for Defendant, COUNTY OF TULARE and
STEVEN HENRY (erroneously sued herein as "PHYSICIANS
ASSISTANT HENRY")

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THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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DONNY Y. EARP,

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Plaintiff,

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COUNTY OF TULARE, PHYSICIANS
ASSISTANT HENRY, and DOES 1-25,

JOINT STIPULATION OF THE
PARTIES; ORDER

vs.

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CASE NO.: 1:11-CV-00196-MJS

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Defendants.

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Case Filed:
Trial Date:
Magistrate:

February 3,2011
June 26, 2012
Michael J. Seng

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The parties to the above referenced action, subject to the Court's approval, hereby stipulate to
the following:
WHEREAS the parties desire to allow for more time to schedule expert witness deposition than
the time frame set out within the Court's July 1, 2011 Scheduling Conference Order;

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WHEREAS the parties have been diligent in conducting discovery, however the designated

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expert witness' respective schedules make it difficult for a mutually agreeable date for all involved

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witnesses and parties to be present before the current expert witness discovery deadline;

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The parties HEREBY AGREE, subject to the Court's approval, to modify the expert discovery
cutoff date contained in the Court's Scheduling Conference Order dated July 1, 2011 as follows:
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The parties will have the right to conduct expert witness depositions up to an including

March 1, 2012. The current expert discovery cut-off date of February 1, 2012 is hereby vacated;
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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER

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The parties also HEREBY AGREE, subject to the Court's approval, that the following dates,
contained in the Court's Scheduling Conference Order dated July 1, 2011 remain as follows:

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1.

The cut-off for fact discovery shall remain February 1, 2012

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2.

The deadline for filing dispositive motions shall remain February 1, 2012

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3.

The deadline for filing non-dispositive motions shall remain February 1, 2012

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4.

The Pre-Trial Conference shall remain June 1, 2012

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5.

The trial date shall remain June 26, 2012.

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The parties further agree that this stipulation may be executed in counterpart and/or facsimile.

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Respectfully submitted,
Dated: January 11, 2012

LeBEAU-THELEN, LLP

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By:
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/s/ KEVIN E. THELEN
KEVIN E. THELEN
Attorneys for Defendants COUNTY OF
TULARE and STEVEN HENRY

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Dated: January 11, 2012

BOURDETTE AND PARTNERS

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By:
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/s/ PHILIP BOURDETTE
PHILIP BOURDETTE
Attorneys for Plaintiff
DONNY Y. EARP

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ORDER

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For good cause shown, the parties' stipulation is approved.

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IT IS SO ORDERED.
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Dated:
ci4d6

January 11, 2012

Michael J. Seng

/s/
UNITED STATES MAGISTRATE JUDGE

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JOINT STIPULATION OF THE PARTIES; [PROPOSED] ORDER