Stroman v. California Department of Corrections and Rehabilitation et al

Filing 49

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 5/27/2015 ORDERING that the parties are permitted to take the deposition of inmate witnesses Darryl Geyer at Valley State Prison, Chowchilla, California or any other California Department of Correction institution to which he may be transferred. (Zignago, K.)

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R I V E R A & A S S O C I AT E S

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2180 Harvard Street, Suite 310
Sacramento, California 95815

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Tel: [phone] Fax: [phone]

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Jesse M. Rivera, SBN 84259
Jonathan B. Paul, SBN 215884
Shanan L. Hewitt, SBN 200168
Jill B. Nathan, SBN, 186136
Jamil Ghannam, SBN 300730

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Attorneys for Defendant,
OFFICER D. BUNCH

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IN THE UNITED STATES DISTRICT COURT

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IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA

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BENJAMIN STROMAN
Plaintiff,

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vs.
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VALLEY STATE PRISON WARDEN
RON DAVIS IN HIS
PERSONAL/INDIVIDUAL
CAPACITY, CDCR CORRECTIONS
OFFICER S. CLEMENT IN HIS
PERSONAL/INDIVIDUAL
CAPACITY, CDCR CORRECTIONS
OFFICER R. FLEMINGIN HIS
PERSONAL/INDIVIDUAL
CAPACITY, CDCR CORRECTIONS
OFFICER D. BUNCH IN HIS
PERSONAL/INDIVIDUAL
CAPACITY, and DOES 1 - 100

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Defendants.
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CASE NO. 2:14-cv-00524 WBS CKD
STIPULATION and [PROPOSED] ORDER
REGARDING DEPOSITION OF INMATE
WITNESS DARRYL GEYER

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TO THE COURT, TO ALL PARTIES AND THEIR COUNSEL OF RECORD:

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Plaintiff Benjamin Stroman (“Plaintiff”) and Defendants Bunch, Clement, and Davis by

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and through their undersigned counsel, hereby stipulate as follows:

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That good cause exists to depose incarcerated witnesses Darryl Geyer.

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Specifically, the parties stipulate that good cause exists to depose the aforementioned

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inmate witness who was identified during the course of plaintiff’s deposition on April 28, 2015

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as having not only witnessed the incident of March 10, 2013 at issue in this case, but who also

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has authored writings and has provided recorded statements regarding the incident.
Hence, the parties stipulate that it is necessary to take the depositions of incarcerated

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prisoner Darryl Geyer, CDC# P-57424 on June 16, 2015 at 9:00 a.m. at Valley State Prison in

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Chowchilla, California, pursuant to F.R.C.P. 30(a)(2)(B).
IT IS SO STIPULATED.

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Dated: May 21, 2015

RIVERA & ASSOCIATES

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/s/ Jonathan B. Paul

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Jonathan B. Paul, Esq.
Attorney for Defendant Bunch

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Dated: May 22, 2015

LAW OFFICES OF BENJAMIN A. WILLIAMS

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/s/ Benjamin A. Williams (as authorized on 5/22/15)

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Benjamin A. Williams, Esq.
Attorney for Plaintiff

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Dated: May 21, 2015

LAW OFFICES OF STEVEN A. GERINGER

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/s/ Steven A. Geringer (as authorized on 5/21/15)

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Steven A. Geringer, Esq.
Attorney for Defendant Clement

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Dated: May 21, 2015

CALIFORNIA OFFICE OF ATTORNEY GENERAL

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/s/ Tiffany Hixson (as authorized on 5/21/15)
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Tiffany Hixson, Esq.
Attorney for Defendants R. Davis

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Stipulation and [Proposed] Order Regarding Deposition of
Inmate Witnesses Darryl Geyer
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[PROPOSED] ORDER

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Having reviewed the above Stipulation, and good cause appearing, IT IS HEREBY

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ORDERED that the parties are permitted to take the deposition of inmate witnesses Darryl

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Geyer at Valley State Prison, Chowchilla, California or any other California Department of

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Correction institution to which he may be transferred.

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IT IS SO ORDERED.

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Dated: May 27, 2015

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation and [Proposed] Order Regarding Deposition of
Inmate Witnesses Darryl Geyer
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