Estate of Stephen E. Crawley et al v. Kings County et al

Filing 39

JOINT STIPULATION AND ORDER TO CONTINUE HEARING DATE RE PLAINTIFF'S MOTION TO COMPEL. The Court set the 37 MOTION to COMPEL for Deposition Testimony and Document Production as to Lemoore Police Department for a Motion Hearing for 5/6/2015 in Courtroom 9 (SAB) before Magistrate Judge Stanley A. Boone. Signed by Magistrate Judge Stanley A. Boone on 4/22/2015. (Hernandez, M)

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William L. Schmidt, SBN. 206870
WILLIAM L. SCHMIDT, ATTORNEY AT LAW, P.C.
377 W. Fallbrook Ave., Suite 205
Fresno, CA 93711
Telephone: [phone]
Facsimile: 559.436.8163
Email: [e-mail]
Attorney for Plaintiffs THE ESTATE OF
STEPHEN E. CRAWLEY, NORMA
CRAWLEY, and JOHNNY CRAWLEY

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Janell Van Bindsbergen
Roy Santos
LOZANO SMITH
7404 North Spalding Avenue
Fresno, CA 93720-3370
Telephone: [phone]
Facsimile: 559.261.9366
Email: [e-mail]

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Attorneys for CITY OF LEMOORE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION
THE ESTATE OF STEPHEN E. CRAWLEY,
NORMA CRAWLEY, individually and as personal
representative of ESTATE OF STEPHEN E.
CRAWLEY, JOHNNY CRAWLEY, individually
and as personal representative of ESTATE OF
STEPHEN E. CRAWLEY
Plaintiff,

Case No. 1:13-CV-02042 LJO-SAB

JOINT STIPULATION TO CONTINUE
HEARING DATE re. PLAINTIFF’S
MOTION TO COMPEL

v.
KINGS COUNTY; KINGS COUNTY SHERIFFS
DEPARTMENT; DAVE ROBINSON, individually,
and in his capacity as Kings County Sheriff;
SHAWN McRAE, individually, and in his capacity
as sergeant for Kings County Sheriff; MARIUS
BARSTECEANU, individually, and in his capacity
as senior deputy for Kings County Sheriff; and
DOES 1-50, inclusive,
Defendants.

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Case No.: 1:13-CV-02042

JOINT STIPULATION TO CONTINUE HEARING DATE re. PLAINTIFFS’ MOTION TO COMPEL

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Plaintiffs THE ESTATE OF STEPHEN E. CRAWLEY, NORMA CRAWLEY, and JOHNNY
CRAWELEY (hereinafter “Plaintiffs”) and THE CITY OF LEMOORE AND OFFICER MICHAEL
KENDALL (hereinafter “City”) hereby submit the following stipulation to modify the operative
scheduling order in this case.
RECITALS
WHEREAS, on April 8, 2015, Plaintiffs’ filed a motion to compel the deposition testimony of
Lemoore Police Department Officer Michael Kendall and the production of documents responsive to
twenty-one requests for production.
WHEREAS, on April 21, 2015, Plaintiffs and City met and conferred about the discovery
disagreement. Discussions were productive and show promise for the potential resolution of this
discovery dispute, and thus may render the present motion to compel unnecessary.
WHEREAS, on April 22, 2015, the parties must submit a joint statement to the court pursuant to
Local Rule 251 no less than 7 days before the scheduled hearing.

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STIPULATION
Now, therefore, IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and
City, through their respective counsel, that the present hearing schedule on this matter be modified to
provide the City Attorney additional time to consult with her client on resolution of the present
discovery disagreement and the parties additional time to draft the joint statement regarding discovery
disagreement as follows:
Last day to submit Joint Statement regarding Discovery Disagreement:

April 29, 2015

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Hearing date for Plaintiffs’ Motion to Compel Deposition Testimony
and Production of Documents:

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May 6, 2015 at 8:30
or a date and time
thereafter.

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Dated: April 22, 2015

WILLIAM L. SCHMIDT, ATTORNEY AT LAW, P.C

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By:

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/s/ William L. Schmidt
William L. Schmidt
Attorney for Plaintiffs
Case No.: 1:13-CV-02042

JOINT STIPULATION TO CONTINUE HEARING DATE re. PLAINTIFFS’ MOTION TO COMPEL

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Dated: April 22, 2015

LOZANO SMITH

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By:

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/s/ Jenell Van Bindsbergen
Jenell Van Bindsbergen
Attorneys for City of Lemoore

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IT IS SO ORDERED.

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Dated:

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April 22, 2015
UNITED STATES MAGISTRATE JUDGE

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Case No.: 1:13-CV-02042

JOINT STIPULATION TO CONTINUE HEARING DATE re. PLAINTIFFS’ MOTION TO COMPEL