Haught v. City of Anderson et al

Filing 67

STIPULATION AND ORDER signed by Judge John A. Mendez on 3/11/2015 ALLOWING the plaintiff to take 11 depositions, instead of 10, as indicated in F.R.Cv.P. Rule 30. (Michel, G.)

1
2
3
4
5
6
7
8

JOHN DOUGLAS BARR……………….
TROY DOUGLAS MUDFORD…………
DAVID LEE CASE………………………
ESTEE LEWIS…………………………..
CATHLEEN T. BARR ...............................
BARR & MUDFORD, LLP
1824 Court Street/Post Office Box 994390
Redding, California 96099-4390
Telephone: [phone]
Fax:
[phone]

California State Bar No. 40663
California State Bar No. 146392
California State Bar No. 56701
California State Bar No. 268358
California State Bar No. 295538

Attorneys for Plaintiff,
KATRINA HAUGHT

9
10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORIA

12
13

KATRINA HAUGHT

14

Plaintiff,

15

vs.

16
17
18
19

No. 2:11-CV-01653-JAM-CMK
STIPULATION AND ORDER TO
EXTEND NUMBER OF DEPOSITIONS
TO BE TAKEN BY PLAINTIFF

THE CITY OF ANDERSON;
THE CITY OF ANDERSON POLICE
DEPARTMENT;
DALE WEBB in his official capacity as
Chief of Police for the City of Anderson
Police Department; and
DOES 1-20.

20
Defendants.

21
22

Plaintiff, KATRINA HAUGHT, and Defendants, THE CITY OF ANDERSON and

23
CHIEF DALE WEBB, by and through their respective counsel of record, hereby stipulate to,
24
25
26
27
28

and respectfully request the Court enter an Order extending the number of depositions to be
taken by plaintiff to 11 depositions, instead of 10 under F.R.C.P. 30.
///
The parties respectfully submit that good cause exists for extending the number of

BARR & MUDFORD
Attorneys at Law
1824 Court Street
Post Office Box 994390
Redding, CA 96099-4390
[phone]

Page 1
Stipulation and Order to Extend Number of Depositions to be Taken by Plaintiff

1

depositions permitted by plaintiff to 11 to allow plaintiff to depose the necessary witnesses in

2

this case. Since the instant action involves an entire police department, and the training and

3

supervision of certain officers, there are dozens of people with pertinent information that could

4

assist plaintiffs. Plaintiffs have done their best to curtail the number of depositions, but given

5
the circumstances surrounding this case, plaintiffs are unable to limit the necessary deponents
6
7
8

to 10 people. Defendants appreciate plaintiff’s situation, and are accommodating plaintiff’s
request accordingly.

9
10
11

IT IS SO STIPULATED:

12
13

DATED: March 11, 2015

BARR & MUDFORD, LLP

14
15

/s/ Cathleen T. Barr
CATHLEEN T. BARR (SBN 295538)
Attorneys for Plaintiff
KATRINA HAUGHT, aka JANE DOE

16
17
18

DATED: March 11, 2015

ANGELO, KILDAY & KILDUFF

19
20
21
22
23

/s/ Bruce A. Kilday
BRUCE A. KILDAY
Attorneys for Defendants,
THE CITY OF ANDERSON; THE CITY OF
ANDERSON POLICE DEPARTMENT; and DALE
WEBB, in his official capacity as Chief of Police for
the City of Anderson Police Department

24
25
26

ORDER

27
28

IT IS HEREBY ORDERED that plaintiff be allowed to take 11 depositions, instead of

BARR & MUDFORD
Attorneys at Law
1824 Court Street
Post Office Box 994390
Redding, CA 96099-4390
[phone]

Page 2
Stipulation and Order to Extend Number of Depositions to be Taken by Plaintiff

1

10, as indicated in F.R.C.P. 30.

2
3
4

DATED: 3/11/2015

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

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
BARR & MUDFORD
Attorneys at Law
1824 Court Street
Post Office Box 994390
Redding, CA 96099-4390
[phone]

Page 3
Stipulation and Order to Extend Number of Depositions to be Taken by Plaintiff