Jewett v. California Forensic Medical Group et al

Filing 126

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 2/27/2018 EXTENDING the briefing deadlines. Plaintiff shall submit the Rule 37(e) motion on 2/21/2018; Defendant Shasta County shall submit its Opposition to Plaintiff's Rule 37(e) motion on 3/14/2018; Plaintiff shall submit his Reply to the Rule 37(e) motion on 3/21/2018; and, the noticed hearing on this matter will be heard on 3/28/2018.(Yin, K)

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KEKER, VAN NEST & PETERS LLP
STEVEN P. RAGLAND - # 221076
[e-mail]
AJAY S. KRISHNAN - # 222476
[e-mail]
TAYLOR GOOCH - # 294282
[e-mail]
FRANCO MUZZIO - # 310618
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
415 391 5400
DISABILITY RIGHTS LEGAL CENTER
MARONEL BARAJAS - #242044
[e-mail]
ANNA RIVERA - # 239601
[e-mail]
MALLORY L. SEPLER-KING – #298262
[e-mail]
350 S. Grand Avenue, Suite 1520
Los Angeles, CA 90071
Telephone:
213 736 1031
ATABEK & ASSOCIATES, P.C.
JON A. ATABEK, ESQ. - # 269497
[e-mail]
300 Spectrum Center Dr., Ste.400
Irvine, CA 92618
Telephone:
213 394 5943
Attorneys for Plaintiffs
EVERETT JEWETT, LEGAL SERVICES
FOR PRISONERS WITH CHILDREN, GLEN
HAROLD EVERETT, MICHAEL DONALD
ACKLEY, HAROLD ROBERT MARQUETTE

BRICKWOOD LAW OFFICE
Gary Charles Brickwood
[e-mail]
1135 Pine Street, Suite 210
Redding, CA 96001
Telephone: [phone]
Attorney for Defendants SHASTA
COUNTY SHERIFF’S DEPARTMENT,
TOM BOSENKO, in his official capacity,
and SHASTA COUNTY

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
EVERETT JEWETT, LEGAL SERVICES
FOR PRISONERS WITH CHILDREN, GLEN
HAROLD EVERETT, MICHAEL DONALD
ACKLEY, HAROLD ROBERT
MARQUETTE, on behalf of themselves and all
others similarly situated,
Plaintiffs,
v.
SHASTA COUNTY SHERIFF’S
DEPARTMENT, a public entity; TOM
BOSENKO, as Sheriff of the Shasta County;
SHASTA COUNTY, a public entity; and
CALIFORNIA FORENSIC MEDICAL
GROUP, INC. a private entity; and DOES 1
through 25, in their individual capacities,
Defendants.

Case No. 2:13-cv-0882 MCE AC (PC)
JOINT STIPULATION AND
[PROPOSED] ORDER EXTENDING
BRIEFING DEADLINES
Judge:

Hon. Allison Claire

Date Filed: May 6, 2013
Trial Date:

JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES
Case No. 2:13-cv-0882 MCE AC (PC)
1250857

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The parties, through their attorneys of record, stipulate and jointly request that the Court

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vacate the current briefing schedule per Local Rule 251(e) and reset all dates from the current

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dates for the following reasons:

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1.

Counsel for Shasta County and Everett Jewett met and conferred on February 14,

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2017 regarding disagreements related to Shasta County’s production of video evidence. The

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parties were unable to resolve their disagreements and determined that they were at an impasse.

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2.

Because the only relief Mr. Jewett seeks is the imposition of sanctions, Local Rule

251(e) applies.

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3.

The parties agreed that an extended briefing schedule was appropriate.

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4.

The parties hereby stipulate and jointly request the Court set the following agreed-

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upon briefing dates for Plaintiff’s Rule 37 motion:

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a. February 21, 2018 – Mr. Jewett to file motion pursuant to FRCP 37(e);

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b. March 14, 2018 – Shasta County’s Opposition due;

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c. March 21, 2018 – Mr. Jewett’s Reply due; and,

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d. March 28, 2018 – Noticed Hearing date.

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5.

The Parties submit concurrently with this stipulation a proposed order for

consideration by the Court.

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Dated: February 21, 2018

Dated: February 21, 2018

KEKER, VAN NEST & PETERS LLP

BRICKWOOD LAW OFFICE

By: /s/ Taylor Gooch__________________
STEVEN P. RAGLAND - # 221076
[e-mail]
AJAY S. KRISHNAN - # 222476
[e-mail]
TAYLOR GOOCH - # 294282
[e-mail]
FRANCO MUZZIO - # 310618
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
415 391 5400

By: /s/ Gary Charles Brickwood (as
authorized on February 20, 2018)
GARY CHARLES BRICKWOOD
[e-mail]
1135 Pine Street, Suite 210
Redding, CA 96001
Telephone: [phone]
Attorney for Defendants SHASTA COUNTY
SHERIFF’S DEPARTMENT, TOM
BOSENKO, AND SHASTA COUNTY

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES
Case No. 2:13-cv-0882 MCE AC (PC)
1250857

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MARONEL BARAJAS - #242044
[e-mail]
ANNA RIVERA - # 239601
[e-mail]
MALLORY L. SEPLER-KING – #298262
[e-mail]
DISABILITY RIGHTS LEGAL CENTER
[e-mail]
350 S. Grand Avenue, Suite 1520
Los Angeles, CA 90071
Telephone:
213 736 1031
JON A. ATABEK, ESQ. - # 269497
ATABEK & ASSOCIATES, P.C.
[e-mail]
300 Spectrum Center Dr., Ste.400
Irvine, CA 92618
Telephone:
213 394 5943
Attorneys for Plaintiffs
EVERETT JEWETT, LEGAL SERVICES
FOR PRISONERS WITH CHILDREN, GLEN
HAROLD EVERETT, MICHAEL DONALD
ACKLEY, HAROLD ROBERT
MARQUETTE

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES
Case No. 2:13-cv-0882 MCE AC (PC)
1250857

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[PROPOSED] ORDER
On February 21, 2018 the parties, through their attorneys of record, filed a Joint

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Stipulation and [proposed] Order Extending Briefing Deadlines. Good cause appearing, the

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motion is granted.

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Accordingly, IT IS HEREBY ORDERED:

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1. Plaintiff Everett Jewett will submit the Rule 37(e) motion on February 21, 2018;

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2. Defendant Shasta County will submit its Opposition to Plaintiff’s Rule 37(e) motion

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on March 14, 2018;
3. Plaintiff Everett Jewett’s shall submit his Reply to the Rule 37(e) motion on March
21, 2018; and,
4. The noticed hearing on this matter will be heard on March 28, 2018.

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IT IS SO ORDERED.

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DATED: February 27, 2018

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JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING BRIEFING DEADLINES
Case No. 2:13-cv-0882 MCE AC (PC)
1250857