Barnes et al vs. County of Placer, et al.,

Filing 68

STIPULATION and ORDER signed by Judge John A. Mendez on 7/29/09 ORDERING Plaintiffs may have through 7/31/09 to file any opposition to the Defendants Motion for Summary Judgment 64 filed 7/10/09. Additional service required under the Local Rules of this court, beyond that provided by e-filing alone, may be made on defendants counsel by e-mail with PDF attachments. Dfts may have through 8/7/09, to file any Reply to the Plaintiffs Opposition to the Defendants Motion for Summary Judgment filed 7/10/09. Additional service required under the Local Rules of this court, beyond that provided by e-filing alone, may be made on plaintiffs counsel by e-mail with PDF attachments. (Carlos, K)

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ROBERT R. POWELL, ESQ. [SBN: 159747] LAW OFFICES OF ROBERT R. POWELL 925 West Hedding Street San José, California 95126 T: 408-553-0200 F: 408-553-0203 ANDREA M. MILLER, ESQ. [SBN: 88992] NAGELEY, MEREDITH & MILLER, INC. 8001 Folsom Boulevard, Suite 100 Sacramento, CA 95826 T: [phone] F: [phone] Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA (Sacramento Division) BRIGIT BARNES, individually and as Guardian Ad Litem for minor children R.X. and M.X, JERRY BARNES, Plaintiffs, v. COUNTY OF PLACER, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:07 CV 01678 JAM-JFM STIPULATION AND ORDER RE: EXTENSION OF TIME TO FILE OPPOSITION AND REPLY ON DEFENDANTS' SUMMARY JUDGMENT MOTION [Dkt.#64]

The parties hereto, by and through their attorneys of record, do hereby agree and stipulate as set forth below, based on the following recital of facts, and request this court order same;

1 Stipulation and Order Re: Extension of Time to File Opposition & Reply to Opposition on Defendant MSJ Barnes v. Placer County

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Recitals: On July 12th, 2009, an associate by the name of Sonia Chabra, employed in the law office of plaintiffs' counsel, suffered a terrible head injury in Santa Cruz, California. So serious were here injuries that she was transported by Life-Flight (by helicopter) to Santa Clara Valley Medical Center. She remained in the Intensive Care Unit for seven days, and was released only last week to her relatives care in Los Angeles, California. Her return to

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work is expected at best to be two weeks longer from this point in time. The office of plaintiffs' counsel has only three attorneys, thus Ms. Chabra's unplanned and involuntary departure created significant havoc with the distribution of tasks and obligations related to pending cases in the office of plaintiffs' counsel. One significant aspect, was that a number of hearings and appearances required to be attended in the Los Angeles and Riverside County areas, which were to be attended by Ms. Chabra, had to be attended by lead counsel in this matter, Mr. Robert Powell. Mr. Powell has in fact now spent seven of the past 13 work days in the Los Angeles area, in matters in both juvenile courts in Riverside County, and Federal Courts in Los Angeles. This has severely hampered preparation of a response to the defendants currently pending Motion for Summary Judgment. Based on the foregoing, the parties, by and through counsel, hereby stipulate and agree, and request this court order as follows: 1. Plaintiffs may have through July 31st, 2009, to file any Opposition to the Defendants

Motion for Summary Judgment filed July 10th, 2009. Additional service required under the Local Rules of this court, beyond that provided by e-filing alone, may be made on defendants' counsel by e-mail with PDF attachments.
2 Stipulation and Order Re: Extension of Time to File Opposition & Reply to Opposition on Defendant MSJ Barnes v. Placer County

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2.

Defendants may have through August 7th, 2009, to file any Reply to the Plaintiffs'

Opposition to the Defendants Motion for Summary Judgment filed July 10th, 2009. Additional service required under the Local Rules of this court, beyond that provided by efiling alone, may be made on plaintiffs' counsel by e-mail with PDF attachments. IT IS SO STIPULATED. Date: 7/29/09 ___/S/ David M. Huskey ____ David M. Huskey, Esq. Attorney for Defendants __/S/ Robert R. Powell______ Robert R. Powell, Esq. Attorney for Plaintiffs

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Date: 7/29/09

ORDER Based on the foregoing stipulation of the parties, and good cause appearing therefore, the court hereby adopts the stipulation of the parties as an order of this court. IT IS SO ORDERED. Date: 7/29/2009 /s/ John A. Mendez______________ JUDGE JOHN A. MENDEZ EASTERN DISTRICT COURT OF CALIFORNIA - SACRAMENTO

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