Hewitt vs. County of Sacramento, et al.,

Filing 64

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 2/17/09: The stipulation re 58 MOTION to COMPEL and 57 MOTION for PROTECTIVE ORDER is APPROVED.(Kaminski, H)

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VAN LONGYEAR, CSB NO. 84189 JENNIFER MARQUEZ, CSB NO. 232194 LONGYEAR, O'DEA AND LAVRA, LLP 3620 American River Drive, Suite 230 Sacramento, Ca. 95864 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants, County of Sacramento (also erroneously sued herein as the Sacramento County Sheriff's Department and Correctional Health Services); Sacramento County Sheriff's Department, Sacramento County Jail Correctional Health Services, Sheriff John McGinness, in his official capacity as Sacramento County Sheriff and individually, Sandra Hand, M.D., in her official capacity as Medical Director of Sacramento County Jail Correctional Health Services and individually, John O'Shaughnessy, in his official capacity as Chief of Sacramento County Jail Correctional Health Services and individually, Tamara Robinson, M.D, Jacqueline Curry, R.N. collectively referred to as County Defendants

LAW OFFICES OF GERI LYNN GREEN, LC GERI LYNN GREEN, SBN 127709 700 Montgomery Street San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs BODE & GRENIER, LLP PETER C. GRENIER, Admitted Pro Hac Vice DOUGLAS C. MELCHER, Admitted Pro Hac Vice 1150 Connecticut Avenue, NW Ninth Floor Washington, DC 20036 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION

J o in t Stipulation W ith d r a w in g Motion for Protective Order [Docket Entry No. 57] and Motion to Compel [Docket Entry No. 58] P age 1

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MARILEE ANN HEWITT, on behalf of herself and on behalf of her deceased son, WILLIAM FRANCIS SAMS, as his successor in interest, and as Administrator of the ESTATE OF WILLIAM FRANCIS SAMS,

) ) ) ) ) ) Plaintiffs ) ) v. ) ) ) COUNTY OF SACRAMENTO, et al. ) ) Defendants. ) ) ) ______________________________________ )

CASE NO: 2:07-CV-01037-DAD DEFENDANT COUNTY OF SACRAMENTO'S, DEFENDANT JACQUELINE CURRY'S, AND PLAINTIFFS' JOINT STIPULATION WITHDRAWING MOTION FOR PROTECTIVE ORDER [DOCKET ENTRY NO. 57] AND MOTION TO COMPEL [DOCKET ENTRY NO. 58] AND ORDER

Defendant County of Sacramento, Defendant Jacqueline Curry, and Plaintiffs hereby submit this Joint Stipulation and Order regarding the Motion for a Protective Order [Docket Entry No. 57] and Motion to Compel Depositions [Docket Entry No. 58] which are currently scheduled to be heard by the Court on February 20, 2009. The parties hereby stipulate that they withdraw their aforementioned motions and request the Court to take those motions off its calendar. Respectfully submitted, Dated: February 17, 2009 LONGYEAR, O'DEA & LAVRA, LLP By: /s/Jennifer Marquez VAN LONGYEAR JENNIFER MARQUEZ Attorneys for County Defendants

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LAW OFFICES OF GERI LYNN GREEN, LC By: /s/ Geri Lynn Green Geri Lynn Green Attorney for Plaintiffs

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Dated: February 17, 2009

BODE & GRENIER, L.L.P. By: /s/ Douglas Melcher Peter C. Grenier Douglas Melcher Attorney for Plaintiffs/admitted pro hac vice

IT IS SO ORDERED. DATED: February 17, 2009.

D d a d 1 /o r d e r s . c o n s e n t/ h e w it t 1 0 3 7 .w i t h d r a w

J o in t Stipulation W ith d r a w in g Motion for Protective Order [Docket Entry No. 57] and Motion to Compel [Docket Entry No. 58] P age 3