Singh, et al v. Sacramento County, et al

Filing 105

STIPULATION and ORDER 103 signed by Judge John A. Mendez on 5/1/12; The parties having entered into a stipulation to a three week extension for Defendant Dietrich to disclose his expert witnesses, and good cause appearing, the due date for Defendant Dietrich to disclose his expert witnesses is now May 18, 2012.(Matson, R)

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R IVERA & A SSOCIATES

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2180 Harvard Street, Suite 310
Sacramento, California 95815

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Tel: [phone] Fax: [phone]

Jesse M. Rivera, SBN 84259
Shanan L. Hewitt, SBN 200168
Jonathan B. Paul, SBN 215884
Attorneys for Defendant,
PETER DIETRICH

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IN THE UNITED STATES DISTRICT COURT

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IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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Estate of BALJIT SINGH, deceased, by and
through PRABJIT SINGH DHANDA, JASJIT
KAUR DHANDA, SUKHJIT KAUR
DHANDA and DAVANJIT SINGH
DHANDA (minors through their mother and
guardian ad litem Amarjit Singh) and
AMARJIT SINGH as successors in interest;
PRABJIT SINGH DHANDA, Individually;
JASJIT KAUR DHANDA, Individually,
DAVANJIT SINGH DHANDA, Individually;
and AMARJIT SINGH, Individually,

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CASE NO.:2:09-cv-01439 JAM JFM
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR DEFENDANT
DIETRICH TO DISCLOSE EXPERT
WITNESSES

Plaintiffs,

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vs.

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COUNTY OF SACRAMENTO, Sacramento
County Sheriff JOHN MCGINNESS;
Sacramento County Main Jail Commander
SCOTT JONES; Sacramento County Sheriff’s
Department Chief of Correctional and Court
Services JAMIE LEWIS; Sacramento County
Chief of Correctional Health Services
ANNMARIE BOYLAN; Sacramento County
Jail System Medical Director DR. PETER
DIETRICH; UC Davis Department of
Psychiatry Chair DR. ROBERT HALES;
Clinical Director of Jail Psychiatric Services
PAUL HENDRICKS; Medical Director of Jail
Psychiatric Services DR. GREGORY
SOKOLOV; L. MICHAEL TOMPKINS;
DONNA L. CHAMPEAUL; and DOES 1 to
40,

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Defendants.

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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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COME NOW THE PARTIES by and through their respective attorneys, hereby stipulate

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to a three week extension for Defendant Dietrich to disclose his expert witnesses. The due date for

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Defendant Dietrich to disclose his expert witnesses is now May 18, 2012.

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IT IS SO STIPULATED.

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Dated: April 30, 2012

RIVERA & ASSOCIATES

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/s/ Jesse M. Rivera
JESSE M. RIVERA
Attorney for Defendant DIETRICH

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Dated:

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LAW OFF OF STEWART KATZ
/s/ Stewart Katz
STEWART KATZ
Attorney for Plaintiffs

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Dated:

LAW OFFICE OF JOSEPH C. GEORGE

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/s/ Joseph C. George
JOSEPH C. GEORGE
Attorney for Plaintiffs

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Dated:

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LONGYEAR, O’DEA & LAVRA, LLP
/s/ Van Longyear
VAN LONGYEAR
JENNIFER MARQUEZ
Attorneys for Defendants
County of Sacramento, John Mc Guinness,
Scott Jones, Jamie Lewis, Ann Marie Boylan

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Dated:
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WILKE, FLEURY, HOFFELT, GOULD &
BIRNEY, LLP
/s/ Robert F. Tyler
ROBERT F. TYLER
Attorneys for Defendants
Robert Hayles, Paul Hendricks,
Gregory Sokolov, L. Michael Tompkins

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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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I, JESSE M. RIVERA HEREBY DECLARE AS FOLLOWS:

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1.

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That I am the Attorney of Record for Defendant, DR. PETER DIETRICH, in the
above entitled matter;

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2.

That I am licensed to practice in all of the courts of the State of California and am

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also authorized to practice in the Federal District Court, Eastern District, State of

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California, as well as the Northern and Central District, State of California. I am also

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authorized to practice in the Ninth and the Eleventh Circuit District Court and the

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United States Supreme Court;

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3.

That I have been retained by the County of Sacramento and County Risk

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Management to represent the interests of Dr. Peter Dietrich in the above referenced

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matter;

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4.

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That Dr. Dietrich was the former Medical Director of the Sacramento County Jail,
Health Services;

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5.

Since the conclusion of discovery on this case on February 28, 2012, Mr. Katz and

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myself had been discussing resolving the portion of the case involving my client, Dr.

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Peter Dietrich.

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6.

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On April 16, 2012 Mr. Katz called my office and we spoke. He advised me he would
be prepared resolve the case against my client;

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7.

I spoke to risk management regarding the settlement offer, who is in charge of

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handling all settlements for the County and their employees. They advised me they

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would accept said offer;

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8.

On April 19, 2012 I communicated the acceptance of this offer to Mr. Katz, both by

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leaving a message at his office and by an e mail accepting his offer. We were

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awaiting Mr. Katz to file the appropriate dismissal with the court;

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9.

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advised to discontinue work on the case and to not author any reports;

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Based on our agreement to resolve Dr. Dietrich’s portion of the case all experts were

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At approximately 3:45 PM on Friday April 27, 2012 Mr. Katz called me on my cell

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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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phone and advised me he was no longer willing to resolve the case of my client from this

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litigation;

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11.

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At the time I received the call I was out of town and I just returned to my office on
April 30, 2012;

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Mr. Katz advised me he understood that expert witness disclosures were due on

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April 30, 2012 and based on the late notification he is prepared to stipulate and allow

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counsel for Dr. Dietrich an extension to disclose experts;

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13.

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Thus on behalf of Dr. Dietrich counsel is seeking an extension of time of 18 days or
up to May 18, 2012 to disclose experts and their reports;

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Counsel will make his experts available for depositions promptly;

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That all counsel in the action are prepared to stipulate to this brief extension.

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I declare the above to be true under penalty of perjury, except as to the matters stated upon

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information and belief, and as to those matters I reasonably believe them to be true.
Executed this 30th

day of April, 2012, in and for the County of Sacramento, California.

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/s/ Jesse M. Rivera
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JESSE M. RIVERA
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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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IN THE UNITED STATES DISTRICT COURT

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IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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Estate of BALJIT SINGH, deceased, by and
through PRABJIT SINGH DHANDA, JASJIT
KAUR DHANDA, SUKHJIT KAUR
DHANDA and DAVANJIT SINGH
DHANDA (minors through their mother and
guardian ad litem Amarjit Singh) and
AMARJIT SINGH as successors in interest;
PRABJIT SINGH DHANDA, Individually;
JASJIT KAUR DHANDA, Individually,
DAVANJIT SINGH DHANDA, Individually;
and AMARJIT SINGH, Individually,

CASE NO.:

CIV-S-05-2134 MCE CMK P

ORDER FOR EXTENSION OF TIME FOR
DEFENDANT DIETRICH TO DISCLOSE
EXPERT WITNESSES

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Plaintiffs,
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vs.
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COUNTY OF SACRAMENTO, Sacramento
County Sheriff JOHN MCGINNESS;
Sacramento County Main Jail Commander
SCOTT JONES; Sacramento County Sheriff’s
Department Chief of Correctional and Court
Services JAMIE LEWIS; Sacramento County
Chief of Correctional Health Services
ANNMARIE BOYLAN; Sacramento County
Jail System Medical Director DR. PETER
DIETRICH; UC Davis Department of
Psychiatry Chair DR. ROBERT HALES;
Clinical Director of Jail Psychiatric Services
PAUL HENDRICKS; Medical Director of Jail
Psychiatric Services DR. GREGORY
SOKOLOV; L. MICHAEL TOMPKINS;
DONNA L. CHAMPEAUL; and DOES 1 to
40,

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Defendants.

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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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The parties having entered into a stipulation to a three week extension for Defendant Dietrich

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to disclose his expert witnesses, and good cause appearing, the due date for Defendant Dietrich to

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disclose his expert witnesses is now May 18, 2012.

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IT IS ORDERED:

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Dated: 5/1/2012

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/s/ John A. Mendez

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The Honorable John A. Mendez

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Judge of the U.S. District Court

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Defendant Dietrich’s Request for Extension of Time to Disclose Expert W itnesses

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