Graham v. City of South Lake Tahoe et al

Filing 36

STIPULATION and ORDER 35 , signed by Judge John A. Mendez on 2/5/11, ORDERING that the time for the parties to submit a joint status report is hereby EXT from 2/25/11 to 3/31/11. (Kastilahn, A)

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RICHARD H. CAULFIELD, SBN 50258 BRIAN C. HAYDON, SBN 154515 ANDREW T. CAULFIELD, SBN 238200 CAULFIELD, DAVIES & DONAHUE, LLP P.O. BOX 277010 Sacramento, CA 95827 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants County of El Dorado and El Dorado County Sheriff's Office (sued herein as El Dorado County Sheriff's Department) UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -o0oSimmone Graham aka Simmone Adelyn Coraham, Plaintiff, Case No. 2:10-CV-02335-JAM-KJM STIPULATION AND PROPOSED ORDER RE MODIFICATION OF ORDER REQUIRING JOINT STATUS REPORT Date: Time: Courtroom: March 9, 2011 9:30 a.m. 6

14 v. 15 16 17 18 19 ______________________________________ 20 21 22 23 24 25 26 27 28 City of South Lake Tahoe, et al., Defendants.

Judge John A. Mendez

Plaintiff SIMMONE GRAHAM aka SIMMONE ADELYN CORAHAM ("Plaintiff"), by and through her undersigned counsel, and Defendants County of El Dorado, City of South Lake Tahoe, City of South Lake Tahoe Police Department, Terry Daniels, California Highway Patrol, Sgt. Sherry, Officer Martain and Officer Lopez (collectively, "Defendants"), by and through their undersigned counsel, hereby stipulate to the following: 1. WHEREAS, Defendants have filed motions to dismiss Plaintiff's Complaint. The

hearing on the motions is currently set for March 9, 2011, at 9:30 a.m., Courtroom 6, before Judge John A. Mendez.

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STIPULATION AND PROPOSED ORDER

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2.

WHEREAS, Paragraph 4 of the Court's Order Requiring Joint Status Report

("Order"), dated August 30, 2010, requires that the parties confer as required by Fed. R. Civ. P. 26(f) and prepare and submit to the court a joint status report that includes the Rule 26(f) discovery plan within sixty (60) days of service of the complaint on any party. 3. WHEREAS, based on service of the Complaint, the deadline identified in Paragraph

4 of the Order is February 25 2011. 4. WHEREAS, the parties collectively desire to extend the time within which they are

obligated to meet and confer and submit a joint status report under Paragraph 4 of the Order to March 31, 2011. 5. WHEREAS, the parties respectfully request that the Court modify its Order and

grant an extension of time for the parties to meet and confer and submit a joint status report under Paragraph 4 of the Order from February 25, 2011 to March 31, 2011. NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1. The time in which the parties must meet and confer and submit a joint status report

under Paragraph 4 of the Order is extended from February 25, 2011 to March 31, 2011. IT IS SO STIPULATED.

Dated: February 25, 2011

CAULFIELD DAVIES & DONAHUE, LLP By:___/s/ Andrew T. Caulfield____ Richard H. Caulfield Andrew T. Caulfield Attorneys for Defendant CITY OF ISLETON P.O. Box 277010 Sacramento, CA 95827 [phone]

[SIGNATURES CONTINUE ON FOLLOWING PAGE]

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Dated: February 25, 2011

O'MARA LAW FIRM By:___/s/ William M. O'Mara ____ (As authorized on 2/24/2011) William M. O'Mara Attorney for Plaintiff Simmone Graham 311 East Liberty Street Reno, NV 89501 [phone]

Dated: February 25, 2011

CITY OF SOUTH LAKE TAHOE By:___/s/ Nira Feeley ___ (As authorized on 2/24/2011) Nira Feeley Attorney Defendants City of South Lake Tahoe, City of South Lake Tahoe Police Department and Terry Daniels 1901 Airport Road, Suite 300 South Lake Tahoe, CA 96150 [phone]

Dated: February 25, 2011

OFFICE OF THE ATTORNEY GENERAL By:___/s/ Catherine Woodbridge Guess__ (As authorized on 2/24/2011) Catherine Woodbridge Guess Attorney for Defendants California Highway Patrol, Sgt. Sherry, Officer Martain and Officer Lopez 1300 I Street, Suite 125 P.O. Box 944255 Sacramento, CA 94244-2550 [phone]

IT IS SO ORDERED. DATED: 2/25/2011 /s/ John A. Mendez____________________ THE HONORABLE JOHN A. MENDEZ UNITED STATES DISTRICT JUDGE
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