Castillo v. Solano County Jail, et al

Filing 85

STIPULATION and ORDER signed by Magistrate Judge Kendall J. Newman on 06/19/12 ordering the timed identified in the court's order dated 05/21/12 requiring that a joint status report be filed by 06/21/12 is now extended by 60 days so that the joint status report is now due on 08/21/12. (Plummer, M)

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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REYNALDO J. CASTILLO,

Case No. 2:08-CV-03080 GEB KJN P

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Plaintiff,

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STIPULATION AND PROPOSED
ORDER RE EXTENSION OF TIME
FOR PARTIES’ JOINT STATUS
REPORT SUBMISSION DEADLINE

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vs.

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SOLANO COUNTY JAIL, et al.,

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Defendants.
________________________________

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Plaintiff Reynaldo Castillo (“Plaintiff”), by and through his undersigned counsel, and
defendants Ravinder Kadevari, M.D., and Chris Pilaczynski (“Defendants”), by and through

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their undersigned counsel, Jerome Varanini (collectively, the “Parties”), hereby agree and

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stipulate to the following:

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1. WHEREAS, Plaintiff’s counsel was appointed by the Court on January 4, 2012,
after discovery was closed;

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2. WHEREAS, Parties have conferred and counsel has agreed that a 60-day

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extension of time to submit a joint status conference statement would be in the best interest

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of the case;

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3. WHEREAS, Plaintiff’s counsel has had a difficult time ascertaining what

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discovery has been propounded and responded to as a result of the Plaintiff’s misplacement
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STIPULATION AND PROPOSED ORDER FOR EXTENSION

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or destruction of parts of the file; and, has had difficulties obtaining documents directly from

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plaintiff;

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4. WHEREAS, Parties’ counsel are working together to ensure that Plaintiff’s

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counsel is in possession of all pertinent documentation, including all medical records

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available so that this matter may be evaluated to determine the necessity of the retention of

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medical expert(s) and/or the possibility of resolution of this matter in order to spare the

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expense involved in prolonged litigation;

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5. WHEREAS, a tragedy in the Plaintiff’s counsel’s family will require significant

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time out of the office and the demands of Plaintiff’s law practice have been extraordinary;

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6. WHEREAS, the recent court order dated May 21, 2012 has required the

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submission of a Joint Status Report to the Court by June 21, 2012;

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7. WHEREAS, the Parties respectfully request that the Court grant an extension of

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time to submit a joint status report to August 21, 2012, or at time that the Court deems

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reasonable.

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8. WHEREAS, this is the first extension requested by Plaintiff.

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THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
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The time identified in the Court’s Order dated May 21, 2012 requiring that a joint

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status report be filed by June 21, 2012, is now extended by sixty (60) days, so that the joint

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status report is now due on August 21, 2012.

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STIPULATION AND PROPOSED ORDER FOR EXTENSION

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IT IS SO STIPULATED.

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Dated: June 20, 2012

COLDERBANK LAW

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By: Tania H. Colderbank
Tania H. Colderbank, Attorney for plaintiff
Reynaldo Castillo

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Dated: June 20, 2012

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TRIMBLE SHERINIAN & VARANINI
By: [signature provided in Dkt. No. 84 at 3]
Jerome Varanini, Attorney for defendants
Ravinder Kadevari, M.D., and Chris Pilaczynski

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IT IS SO ORDERED.

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Date: 6/19/2012
_____________________________________
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE

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DEAC_Signature-E ND:

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STIPULATION AND PROPOSED ORDER FOR EXTENSION