Caruso v. Johnson et al

Filing 257

STIPULATION AND ORDER RE: AMENDMENTS TO PRETRIAL ORDER (ECF NO. 239 ) signed by District Judge Anthony W. Ishii on 7/23/2020. (Gonzales, V)

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XAVIER BECERRA, State Bar No. 118517
Attorney General of California
R. LAWRENCE BRAGG, State Bar No. 119194
Supervising Deputy Attorney General
DERREK J. LEE, State Bar No. 297497
CASSANDRA J. SHRYOCK, State Bar No. 300360
Deputy Attorneys General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
Solorio, Ingram, Martinez, and Lopez
Jenny C. Huang, SBN 223596
Jessica T. Arena, SBN 301807
JUSTICE FIRST
180 Grand Avenue, Suite 1300
Oakland, CA 94612
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiff Gina Caruso

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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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GINA CARUSO,

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v.

Case No. 1:15-cv-00780-AWI-EPG
Plaintiff, STIPULATION AND [PROPOSED]
ORDER RE: AMENDMENTS TO
PRETRIAL ORDER (ECF NO. 239)

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G. SOLORIO, et al.,
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Defendants.
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By and through their counsel, the parties have stipulated that Dr. Romero is considered to

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be an identified witness for both Defendants and Plaintiff. Dr. Romero was previously only

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identified in the pretrial statement as a witness on Plaintiff’s behalf. Dr. Romero will testify as to

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her observations of Plaintiff and as a percipient witness only, consistent with her prior deposition

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testimony.
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Stipulation and [Proposed] Order (1:15-cv-00780-AWI-EPG)

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The parties also agree to add the following exhibits to Plaintiff’s exhibit list:

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1. Two photos taken of Plaintiff’s cell in Administrative Segregation (IMG Nos. 3157 and
3158);

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2.

Photo #12 attached to Incident Report by Lieutenant Villegas (of contraband); and

3. Decision and Order by the California Board of Registered Nursing re: Nurse Franco,
dated May 28, 2019.

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Dated: July 23, 2020

/s/ Derrek J. Lee
Derrek J. Lee
Counsel for Defendants Ingram, Martinez,
Solorio, and Lopez

Dated: July 23, 2020

/s/ Jenny Huang
Jenny Huang
Counsel for Plaintiff Gina Caruso

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IT IS SO ORDERED.
Dated: July 23, 2020
SENIOR DISTRICT JUDGE

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Stipulation and [Proposed] Order (1:15-cv-00780-AWI-EPG)