Goins et al v. County of Merced et al

Filing 39

STIPULATION and ORDER EXTENDING Non-Expert Discovery Cut-Off. Pursuant to the terms of the parties' stipulation, the deadline for non-expert discovery is extended to April 30, 2015. No other deadlines have been modified. Order signed by Magistrate Judge Sheila K. Oberto on 3/16/2015. (Timken, A)

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WILLIAM J. SMITH #056116
SMITH JOHNSON, INC.
5588 N. Palm Avenue
Fresno, California 93704
[phone] Telephone
[phone] Facsimile

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Attorneys for Plaintiffs, DIANE GOINS and WESLEY RENTFROW

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KROLOFF, BELCHER, SMART,
PERRY & CHRISTOPHERSON
LAURIE BELL SCHRUM, SBN 165924
7540 Shoreline Drive
Stockton, CA 95219
Phone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant Merle Wayne Hutton

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James N. Fincher, SBN 196837
Merced County Counsel
Roger S. Matzkind, SBN 77331
Chief Civil Litigator
2222 M Street, Room 309
Merced, CA 95340
Tel: [phone]
Fax: [phone]

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Attorney for County of Merced and
Merced County District Attorney, a department of the County of Merced

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United States District Court

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Eastern District of California

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Diane Goins, et al.,
Plaintiff(s),

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v.

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Stipulation and Order Extending Nonexpert Discovery Cut-off

County of Merced, et al.,

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Case No. 1:13-cv-01245 AWI SKO

Defendants.

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Stipulation and Order Extending Non-expert Discovery Cut-off

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WHEREAS, Defendant County of Merced granted Plaintiffs an extension

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of time to respond to written discovery as a result of Mr. Smith’s representations

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that he was having administrative issues in his office; and,

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WHEREAS, a discovery dispute arose between Plaintiffs and Defendants

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as a result of what Defendants believe to be insufficiencies in Plaintiffs’ discovery

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responses and that the parties are attempting to resolve such dispute without

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involving the court; and,

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WHEREAS, Defendants according to Mr. Smith, Plaintiffs’ supplemental
responses to written discovery were delayed due to the death of plaintiffs’
counsel’s mother-in-law and his serious health condition; and,
WHEREAS, Defendants needed Plaintiffs’ discovery responses prior to the
depositions of Plaintiffs; and,
WHEREAS the depositions of witnesses were delayed due to the delay in
Plaintiffs’ written discovery responses and production; and,
WHEREAS two of the witnesses Plaintiffs want to depose are no longer
employed by the County of Merced; and,
WHEREAS the witness depositions have not been completed due to the
delays;
NOW THEREFORE it is stipulated between William J. Smith, counsel for

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plaintiffs, Roger S. Matzkind, counsel for defendant County of Merced, and

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Laurie Bell Schrum, counsel for defendant Merle Wayne Hutton, that the time for

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completion of non-expert witness depositions and motions to compel written

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discovery and depositions be extended as follows:
Current Deadline

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Non-Expert discovery deadline for

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April 30, 2015

motions to compel written discovery

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April 3, 2015

non-expert witness depositions and

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Stipulated Deadline

and depositions :

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Stipulation and Order Extending Non-expert Discovery Cut-off

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Dated: March 13, 2015

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Smith Johnson, Inc.
By:

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/s/ William J. Smith (as authorized 3/13/15)
William J. Smith
Attorney for Plaintiffs,
Diane Goins and Wesley Rentfrow

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Dated: March 13, 2015

Kroloff, Belcher, Smart, Perry & Christopherson

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By:

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Dated: March 13, 2015

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James N. Fincher
Merced County Counsel
By:

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/s/ Laurie Bell Schrum (as authorized 3/13/15)
Laurie Bell Schrum
Attorney for Defendant,
Merle Wayne Hutton

/s/ Roger S. Matzkind
Roger S. Matzkind
Chief Civil Litigator
Attorneys for Defendant County of Merced
and Merced County District Attorney, a
department of the County of Merced

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ORDER

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Pursuant to the terms of the parties' stipulation, the deadline for non-

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expert discovery is extended to April 30, 2015. No other deadlines have been

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modified.

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IT IS SO ORDERED.
Dated:

March 16, 2015

/s/ Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Order Extending Non-expert Discovery Cut-off