Hunt v. County of El Dorado et al

Filing 93

STIPULATION and ORDER 92 signed by Judge John A. Mendez on 6/12/2012 STRIKING allegations contained in plaintiff's 51 Third Amended Complaint. (Marciel, M)

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Douglas E. Watts, SBN 182274
WATTS LAW OFFICES
2320 E. Bidwell St., Suite 110
Folsom, CA 95630
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Stephen M. Murphy, SBN 103768
LAW OFFICES OF STEPHEN M. MURPHY
353 Sacramento Street, Suite 1140
San Francisco, CA 94111
Phone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff: TANYA HUNT

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A PROFESSIONAL CORPORATION
Nancy J. Sheehan, SBN 109419
Stephen E. Horan, SBN 125241
Beatriz Berumen, SBN 271249
350 University Ave., Suite 200
Sacramento, California 95825
Telephone: [phone]
Facsimile: [phone]
E-mails: [e-mail]; [e-mail]
Attorneys for Defendants: COUNTY OF EL DORADO

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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TANYA HUNT,

CASE NO. 2:10−CV−01367−JAM −CKD

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Plaintiffs,
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vs.

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COUNTY OF EL DORADO; PHIL
CHOVANEC; DARIN LEWIS; KEVIN
HOUSE; BOB ASHWORTH; JACKIE
NOREN, and Does 1 through 50, inclusive

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Defendants.

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STIPULATION TO STRIKE ALLEGATIONS
CONTAINED
IN
PLAINTIFF’S
THIRD
AMENDED COMPLAINT; ORDER THEREON

Complaint Filed:
First Amended Compl. Filed:
Second Amended Compl. Filed:
Third Amended Compl. Filed:
Trial Date:

06/03/2010
10/14/2010
01/27/2011
04/16/2011
03/04/2013

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STIPULATION TO STRIKE ALLEGATIONS CONTAINED IN PLAINTIFF’S THIRD AMENDED COMPLAINT;
[PROPOSED] ORDER THEREON
{01019072.DOC}

PDF created with pdfFactory trial version www.pdffactory.com

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The parties, by and through their counsel, hereby stipulate to strike the following portions of the
Third Amended Complaint:

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1.

Allegations at ¶¶ 24 -29, relating to Plaintiff’s personal loss and the contention that male

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deputies suffering similar losses were treated more favorably;
2.

Allegations at ¶¶ 30-36, relating to Plaintiff’s contention that she was targeted for

discipline because she complained to the EDSO male leadership about its handling of the Deputy

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Melissa Meekma Tragedy;
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3.

Allegations at ¶¶ 37-38, relating to Hunt’s marital status and that she was treated

differently depending on that status.
IT IS SO STIPULATED.
Dated: June 1, 2012

WATTS LAW OFFICES

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By:

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Dated: June 8, 2012

/s/Douglas E. Watts (authorized on 06/01/12)
Douglas E. Watts
Attorney for Plaintiff
TANYA HUNT

LAW OFFICES OF STEPHEN M. MURPHY

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By:
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/s/Stephen M. Murphy (authorized on 06/08/12)
Stephen M. Murphy
Co-Attorney for Plaintiff
TANYA HUNT

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Dated: June 12, 2012
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PORTER SCOTT
A PROFESSIONAL CORPORATION

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By:

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/s/Beatriz Berumen
Nancy J. Sheehan
Stephen E. Horan
Beatriz Berumen
Attorneys for Defendants
COUNTY OF EL DORADO and
FRED KOLLAR
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STIPULATION TO STRIKE ALLEGATIONS CONTAINED IN PLAINTIFF’S THIRD AMENDED COMPLAINT;
[PROPOSED] ORDER THEREON
{01019072.DOC}

PDF created with pdfFactory trial version www.pdffactory.com

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ORDER
Pursuant to the parties’ Stipulation, the allegations at the referenced paragraphs in the above
Stipulation are stricken.
IT IS SO ORDERED.

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Dated: 6/12/2012

/s/ John A. Mendez_____________
JOHN A. MENDEZ
United States District Court Judge

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STIPULATION TO STRIKE ALLEGATIONS CONTAINED IN PLAINTIFF’S THIRD AMENDED COMPLAINT;
[PROPOSED] ORDER THEREON
{01019072.DOC}

PDF created with pdfFactory trial version www.pdffactory.com