Arnold v. County of Sacramento et al
Filing
37
STATUS REPORT by County of Sacramento, Sacramento Public Library Authority. (Paul, Jonathan)
1
Rivera&Associates
2
2 18 0 Har var d Str eet, Suite 3 1 0
Sacr amento , Califor nia 95 815
3
Tel: 916 -9 22 -1 2 0 0 Fax: 9 1 6 9 2 2 -1 3 0 3
4
J es s e M . R i vera, C S N 84259
J onat han B. P aul , CS N 21 5884
S h anan L. Hewi t t , CS N 200168
Kel ly A. Yokl ey, C S N 192015
5
6
7
8
Attorneys for Defendants,
County of Sacramento and Sacramento Public Library Authority
9
IN THE UNITED STATES DISTRICT COURT
10
IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA
11
12
CONNIE ARNOLD,
13
14
Plaintiff,
vs.
15
COUNTY OF SACRAMENTO, et al.
16
Defendant.
17
18
19
)
)
)
)
)
)
)
)
)
)
)
CASE NO. 2:12-cv-01998-LKK-EFB
UPDATED STATUS REPORT OF
DEFENDANTS COUNTY OF
SACRAMENTO AND SACRAMENTO
PUBLIC LIBRARY AUTHORITY
Scheduling Conference: April 29, 2013
Time: 10:00 a.m.
Location: Courtroom 4
Before: Honorable Lawrence K. Karlton
Defendants County of Sacramento and Sacramento Public Library Authority (hereinafter
“defendants”) hereby submit their updated status report.
20
Summary of Facts
21
Plaintiff Connie Arnold has brought the subject action alleging violation of the
22
Americans with Disabilities Act (ADA) - Title II, as well as other federal and state claims. Ms.
23
Arnold, who claims to be a person with a mobility disability and requires the use of the a
24
wheelchair, claims to have been denied access at the Sylvan Oaks Public Library and
25
Crosswoods Park in the City of Citrus Heights, within the County of Sacramento. Plaintiff
26
claims that denial of access took place in September 2011 and that she has been deterred from
27
returning to the park and library since that time.
28
///
Updated Status Report of Defendants County of Sacramento and Sacramento Public Library Authority - Page 1
1
Anticipated Discovery
2
On January 11, 2013, the parties undertook a joint inspection of the Crosswoods Park and
3
Sylvan Oaks Public Library prior to formal discovery. Thereafter on April 1, 2013, Plaintiff put
4
forth her demand for injunctive relief to defendants. Said demand is currently under
5
consideration by defendants’ principals and defendants believe that early resolution of this matter
6
may be possible without the need for formal discovery. Defendants would ask that this matter be
7
set for a settlement conference within thirty days of the scheduling conference to avoid otherwise
8
unnecessary discovery. However, in acknowledgment of the Court’s need to set forth a litigation
9
schedule defendants propose the following discovery and scheduling plan:
10
Initial Scheduling Conference:
April 29, 2013
11
30-Day Discovery Stay Until:
May 29, 2013
12
Fact Discovery Cut-off:
November 25, 2013
13
Expert Disclosures:
January 24, 2014
14
Rebuttal Expert Disclosures:
February 24, 2014
15
Expert Discovery Cut-off:
April 24, 2014
16
Last Day to File Dispositive Motions:
June 23, 2014
17
Jury Trial:
October 21, 2014
18
Future Proceedings
19
Defendants are informed and believe that this is a limited disabled access claim for purely
20
injunctive relief. As such, the parties agreed to initially conduct the joint inspection and attempt
21
to resolve the case under the schedule proposed above. Based upon the demand made by
22
plaintiff following the joint inspection, defendants request the assistance of a magistrate judge for
23
an early settlement conference before engaging in formal discovery.
24
Dated: April 15, 2013
Respectfully submitted,
25
RIVERA & ASSOCIATES
26
/s/ Jonathan B. Paul
By:
27
28
JONATHAN B. PAUL
Attorney for County of Sacramento and
Sacramento Public Library Authority
Updated Status Report of Defendants County of Sacramento and Sacramento Public Library Authority - Page 2
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?