Tandel v. County of Sacramento, et al

Filing 171

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 06/16/15 ORDERING that dates are EXTENDED as follows: Joint Final Pretrial Statement and Procedural and Evidentiary Motions due 07/09/15; Trial Briefs and Oppositions due 07/16/15; Replies due 07/23/15. (Benson, A)

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GERI LYNN GREEN – (SBN 127709)
LAW OFFICES OF GREEN & GREEN, LLP
4 Embarcadero Center, Suite 1400
San Francisco, California 94111
Tel:[phone]
Fax:[phone]
[e-mail];
[e-mail]
Attorneys for Plaintiff
Sandipkumar Tandel

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CASE NO. 2:11-cv-00353 MCE AC

SANDIPKUMAR TANDEL,

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Plaintiff,

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vs.

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JOINT STIPULATION AND FOR
EXTENSION OF TIME FOR THE
FILING OF TRIAL DOCUMENTS;
ORDER THEREON

COUNTY OF SACRAMENTO, et al.,

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Defendants.

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Plaintiff, Sandipkumar Tandel, is represented by Geri Green of the Law Offices of Green
& Green LLP, and Dennise S. Henderson of the Law Office of Dennise S. Henderson.
Defendants, Attorneys for Defendants County of Sacramento, John McGinness, Deputy
Stephanie Jacoby and Deputy Mark Medeiros are represented by Van Longyear and Peter C.
Zilaff of Longyear, O’Dea & Lavra, LLP.
The parties are mindful of the extensive length of trial and the Court’s impacted criminal
trial calendar. The parties met and conferred and requested in a pending stipulation that the trial
and pre-trial dates be continued to February 2016 in the interest of judicial economy. (Dkt. 168)
While that stipulation remains under submission, on June 4, 2015, on its own motion vacated the

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August 31, 2015, jury trial date and continued it to September 8, 2015, and vacated and

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continued the July 9, 2015, Final Pretrial Conference date to July 30, 2015. (Dkt.169.)

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The Court left all other due dates set forth in the Court's November 12, 2014 Order Continuing
Trial. (Dkt.164.)
The parties now, jointly, request that the due dates for the trial documents be extended for

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21 days to correspond to the new date for the Final Pretrial Conference. This request is made on

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the basis that the parties are engaging and meaningful discussions and collaborations concerning

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numerous stipulations that would decrease the length of time required to try this case. The

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stipulations require more time and collaboration between the parties.

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Ms. Green has just returned to her office after being away for three weeks. Her father

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and former law partner is gravely ill and declining rapidly requiring her attention. She is also ill
making collaboration difficult at this time. While she is expected to recover, her father, likely,

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will not. Consequently, the parties request that the filing dates for the trial documents track the

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new Final Pretrial Conference date and be extended for 21 days as follows:

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Documents

Present Date Due

Requested Date

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Joint Final Pretrial Statement
Procedural and Evidentiary Motions

June 18, 2015

July 9, 2015

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Trial Briefs and Oppositions

June 25, 2015

July 16, 2015

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Replies

July 2, 2015

July 23, 2015

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This request is made on the assumption that the Court's calendar will not be adversely

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affected by the requested continuance in light of the Court's continuance of the Final Pretrial

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Conference and trial dates.

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///

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Joint Stipulation and [Proposed] Order
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IT IS SO STIPULATED:

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Dated: June 15, 2015

LAW OFFICES OF GREEN & GREEN LLP
/S/: Geri Green_______________
GERI GREEN
Attorneys for Plaintiff

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Dated: June 2, 2015

LONGYEAR, O’DEA & LAVRA, LLP
/S/: Peter C. Zilaff______________
PETER C. ZILAFF
Attorneys for Defendants,
County of Sacramento, et al.

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IT IS SO ORDERED.

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Dated: June 16, 2015

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Joint Stipulation and [Proposed] Order
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