Fox et al v. Anderson et al

Filing 44

STIPULATION and ORDER 43 signed by Judge John A. Mendez on 7/9/12 ORDERING that defendants have up to and including 7/20/12, to comply with the Discovery Order dated 6/8/12.(Matson, R)

1
2
3
4
5

A PROFESSIONAL CORPORATION
Terence J. Cassidy, SBN 99180
John R. Whitefleet, SBN 213301
350 University Ave., Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

Attorneys for Defendants

6
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11
12

BARRY FOX, NARCISA FOX, individually
and as parents and natural guardians and
Guardians ad litem of A.F., D.F., S.F. AND
M.F., minors,

13

Case No. 2:11-cv-00419-JAM-KJN
STIPULATION
COMPLIANCE
ORDER

AND ORDER FOR
WITH DISCOVERY

Plaintiffs,

14

vs.

15

COUNTY OF SACRAMENTO, SCOTT
ANDERSON, R. COCKERTON, B.
MCATEE, ELISA OLMO, SOKA OM,
JASON WALKUP, JOY PIKE, CITY OF
R A N C H O C O R D O V A , J AS M IN E
DELGADO and DOES 1 THROUGH 30,

16
17
18

Defendants.
19

/

20

IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs BARRY FOX,

21

and NARCISA FOX, and Defendants COUNTY OF SACRAMENTO, SCOTT ANDERSON,

22

RICH COCKERTON, BRENDAN MCATEE, and CITY OF RANCHO CORDOVA, by through

23

their respective undersigned counsel:

24

1.

In its Order dated June 8, 2012, the court required the County of Sacramento

25

provide certain statistical data, if available. The court noted the parties may file a stipulation

26

and proposed order extending the deadline for production and declaration(s) to be delivered

27

to plaintiffs. Defendants sought reconsideration of this order. The District Court denied

28
1

PORTER * SCOTT
ATTORNEYS
3 5 0 U N IV E R S I T Y A V E ., S U I T E 2 0 0
SACRAM EN T O , CA 95825
T E L : 9 1 6 . 9 2 9 .1 4 8 1
F A X : 9 1 6 . 9 2 7 .3 7 0 6

www.porterscott.com

STIPULATION AND [PROPOSED] ORDER TO M ODIFY DEADLINE FOR COM PLIANCE W ITH
DISCOVERY ORDER
01033051.WPD

1

Defendants’ Motion for Reconsideration on July 9, 2012.

2

respectfully request that the deadline for Defendants to comply with the Order dated June 8,

3

2012, be extended to July 20, 2012.

4
5
6

2.

Accordingly, the parties

The parties further agree Plaintiffs have up to and including July 20, 2012 to

provide responses to written discovery propounded by Defendants.
IT IS SO STIPULATED.

7
8

DATED: July 9, 2012

LAW OFFICES OF LANNY T. WINBERRY

9
10

By

11

/s/ Lanny T. Winberry
Lanny T. Winberry (as authorized on July 9, 2012)
Attorney for Plaintiffs

12
13
DATED: July 9, 2012
14

PORTER SCOTT
A Professional Corporation

15
By
16
17

/s/ John R. Whitefleet
Terence J. Cassidy
John R. Whitefleet
Attorneys for Defendants

18
19
20

ORDER
Having reviewed the above stipulation and good cause appearing therefor, IT IS HEREBY

21
ORDERED that Defendants have up to and including July 20, 2012, to comply with the Discovery
22
Order dated June 8, 2012.
23
IT IS SO ORDERED.
24
DATED: 7/9/2012
25
/s/ John A. Mendez
John A. Mendez
United States District Court Judge

26
27
28

2

PORTER * SCOTT
ATTORNEYS
3 5 0 U N IV E R S I T Y A V E ., S U I T E 2 0 0
SACRAM EN T O , CA 95825
T E L : 9 1 6 . 9 2 9 .1 4 8 1
F A X : 9 1 6 . 9 2 7 .3 7 0 6

www.porterscott.com

STIPULATION AND [PROPOSED] ORDER TO M ODIFY DEADLINE FOR COM PLIANCE W ITH
DISCOVERY ORDER
01033051.WPD

1
2
3

Case Name: Fox, et al. v. Anderson, et al.
Case No.:
USDC EDCA 2:11-CV-00419 JAM-KJN

4
DECLARATION OF SERVICE
5
6

I am a citizen of the United States and employed in Sacramento County, California; I am over
the age of 18 years and not a party to the within action; my business address is 350 University
Avenue, Suite 200, Sacramento, California 95825.

7
On the date below I caused to be served the attached:
8
9

STIPULATION AND [PROPOSED] ORDER FOR COMPLIANCE WITH DISCOVERY
ORDER

10
11

XXX

BY MAIL: I caused such envelope with postage thereon fully prepaid to be placed
in the United States mail at Sacramento, California.

12

BY PERSONAL SERVICE: I caused such document to be delivered by hand to
the office of the person(s) listed below.

13
14

BY OVERNIGHT DELIVERY: I caused such document to be delivered by
overnight delivery to the office of the person(s) listed below.

15

BY FACSIMILE: I caused such document to be transmitted by facsimile machine
to the office of the person(s) listed below.

16
17

addressed as follows:

18

Yasmin Delgado
2683 Aramon Drive
Rancho Cordova, CA 94570

19
20
21
22

I declare under penalty of perjury that the foregoing is true and correct and was executed on
July 9, 2012, at Sacramento, California.

23
24
25

/s/ Ramina German
Ramina German

26
27
28
3

PORTER * SCOTT
ATTORNEYS
3 5 0 U N IV E R S I T Y A V E ., S U I T E 2 0 0
SACRAM EN T O , CA 95825
T E L : 9 1 6 . 9 2 9 .1 4 8 1
F A X : 9 1 6 . 9 2 7 .3 7 0 6

www.porterscott.com

STIPULATION AND [PROPOSED] ORDER TO M ODIFY DEADLINE FOR COM PLIANCE W ITH
DISCOVERY ORDER
01033051.WPD