Singh, et al v. Sacramento County, et al

Filing 95

STIPULATION and ORDER signed by Judge John A. Mendez on 12/22/2011 MODIFYING 65 Amended Status (Pre-Trial Scheduling) Order: Non-Expert Discovery due 2/29/2012; Disclosure of Expert Witnesses due by 4/16/2012; Disclosure of Supplemental Expert Witn esses due by 5/7/2012; Expert Discovery due by 5/31/2012; Dispositive Motions to be filed by 7/16/2012; Objections to Dispositive Motions due by 8/6/2012, Replies due by 8/20/2012; Dispositive Motions to be heard by 9/5/1012; Joint Pretrial Statement due by 11/2/2012; Final Pretrial Conference RESET for 11/9/2012 at 10:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez; Jury Trial RESET for 1/14/2013 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Michel, G)

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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 JAM JFM
STIPULATION AND ORDER FOR
MODIFICATION OF PRETRIAL
SCHEDULING ORDER [DOCKET NO.
65]
*AS MODIFIED BY THE COURT

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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 September 6, 2011 (Doc. No. 65).

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The parties propose the following schedule:

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February 29, 2012.
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That the expert witness disclosure cut-off date currently set for January 30, 2012 be
moved to April 16, 2012.

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That the non-expert discovery cut-off date currently set for April 26, 2012 be moved to

That the supplemental expert witness disclosure cut-off date currently set for February 21,
2012 be moved to May 7, 2012.

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That the expert discovery cut-off date be moved to May 31, 2012 (there is no expert

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discovery cut-off date specified in Docket No. 65 other than the general discovery cut-off

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date of April 26, 2012).

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That the dispositive motion filing date currently set for June 13, 2012 be moved to July
16, 2012.

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Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 65]
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6, 2012.
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That the Joint Pretrial Statement currently due on August 24, 2012 be moved to
* November 2, 2012.

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That the last day to hear dispositive motions currently set for July 11, 2012 be moved to
* September 5, 2012 at 9:30 a.m.

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

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That the last day to file and serve an opposition to dispositive motions be set for August

That the Final Pretrial Conference currently set for August 31, 2012 at 11:00 AM be
moved to November 9, 2012, at *10:00 AM.

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That the Trial date currently set for November 5, 2012 be moved to January 14, 2013 at
9:00 a.m.

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This calendaring modification is requested because of the limited availability of both

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plaintiffs’ counsel and defense counsel due to trials in other cases and calendaring conflicts

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regarding same.

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IT IS SO STIPULATED.

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Dated: December 21, 2011

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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: December 21, 2011

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

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Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 65]
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Dated: December 21, 2011

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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: December 21, 2011

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

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.

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Dated: December 21, 2011

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

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IT IS SO ORDERED *AS MODIFIED BY THE COURT
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Dated: December 22, 2011
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/s/ John A. Mendez_______
John A. Mendez
United States District Judge

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Stipulation And (Proposed) Order For Modification Of Pretrial Scheduling Order [Docket No. 65]
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