Singh, et al v. Sacramento County, et al

Filing 110

STIPULATION AND ORDER signed by Judge John A. Mendez on 6/1/12: Designation of Expert Witnesses due by 6/15/2012. Dispositive Motions filed by 7/30/2012. (Kaminski, H)

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LONGYEAR, O’DEA & LAVRA, LLP
Van Longyear, SBN 84189
Jennifer Marquez, SBN 232194
3620 American River Drive, Suite 230
Sacramento, CA 95864
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
County of Sacramento, John McGinness,
Scott Jones, Jamie Lewis, AnnMarie Boylan

LAW OFFICE OF JOSEPH C. GEORGE
Joseph C. George, Sr., SBN 119231
Joseph George, Jr., SBN 200999
2431 Capitol Avenue
Sacramento, CA 95816
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

LAW OFFICE OF STEWART KATZ
Stewart Katz, SBN 127425
Guy Danilowitz, SBN 257733
555 University Avenue, Suite 270
Sacramento, CA 95825
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

RIVERA & ASSOCIATES
Jesse M. Rivera, SBN 084259
2180 Harvard Street, Ste. 310
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant,
Peter Dietrich

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WILKE, FLEURY, HOFFELT, GOULD
& BIRNEY, LLP
Robert F. Tyler, SBN 063055
400 Capitol Mall, 22nd Floor
Sacramento, CA 95814
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants,
Robert Hales, Paul Hendricks, Gregory
Sokolov, and Dr. L. Michael Tompkins

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UNITED STATES DISTRICT COURT

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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;
SUKHJIT KAUR DHANDA, Individually;
DAVANJIT SINGH DHANDA,
Individually; and AMARJIT SINGH,
Individually,
Plaintiffs,

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CASE NO. 2:09-CV- 1439
STIPULATION AND ORDER FOR
MODIFICATION OF PRETRIAL
SCHEDULING ORDER [DOCKET NO.
95]

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v.

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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 Direct of Jail
Psychiatric Services PAUL HENDRICKS;
Medical Director of Jail Psychiatric Services
DR. GREGORY SOKOLOV; L. MICHAEL
TOMPKINS; and Does 1 to 40, inclusive,

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Defendants.
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COME NOW THE PARTIES by and through their respective counsel and subject to the

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approval of this Court, hereby stipulate and respectfully request the following modifications to

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this Court’s Pretrial Scheduling Order of December 22, 2011 (Doc. No. 95).

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The parties propose the following schedule:

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•

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15, 2012.
•

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•

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That the last day to file and serve an opposition to dispositive motions currently set for
August 6, 2012 be moved to August 20, 2012.

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That the dispositive motion filing date currently set for July 16, 2012 be moved to July
30, 2012.

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That the expert discovery cut-off date currently set for May 31, 2012 be moved to June

That the last day to file and serve a reply to an opposition to dispositive motions currently
set for August 20, 2012 be moved to September 6, 2012.

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That the last day to hear dispositive motions currently set for September 5, 2012 at 9:30
a.m. be moved to September 19, 2012 at 9:30 a.m.

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Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 95]
Page 2

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This calendaring modification is requested because the parties are unable to comply with

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the May 31, 2012 deadline for expert discovery due to the experts’ limited availability and travel

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required as three experts are located out of state. The parties agree to extend all deadlines

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approximately two weeks to allow the parties sufficient time for deadlines regarding dispositive

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motions and to provide the Court sufficient time to review said motions.

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IT IS SO STIPULATED.

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Dated: May 31, 2012

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LAW OFFICE OF STEWART KATZ
By: /s/ Stewart Katz
STEWART KATZ
Attorneys for Plaintiffs

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.

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Dated: May 31, 2012

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LAW OFFICE OF JOSEPH C. GEORGE
By: /s/ Joe George
JOSEPH C. GEORGE, SR.
Attorneys for Plaintiffs

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.

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Dated: May 31, 2012

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LONGYEAR, O’DEA & LAVRA, LLP
By: /s/ Van Longyear
.
VAN LONGYEAR
JENNIFER MARQUEZ
Attorneys for Defendants,
County of Sacramento, John McGinness,
Scott Jones, Jamie Lewis, AnnMarie Boylan

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Dated: May 31, 2012

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RIVERA & ASSOCIATES
By: /s/ Jesse Rivera
JESSE M. RIVERA
Attorneys for Defendant,
Peter Dietrich

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Dated: May 31, 2012
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WILKE, FLEURY, HOFFELT, GOULD & BIRNEY,
LLP

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By: /s/ Robert Tyler
.
ROBERT F. TYLER, JR.
Attorneys for Defendants,
Robert Hales, Paul Hendricks,
Gregory Sokolov, L. Michael Tompkins
Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 95]
Page 3

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IT IS SO ORDERED.

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Dated: 6/1/2012

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/s/ John A. Mendez____________
John A. Mendez
United States District Court Judge

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Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 95]
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