A.T. v. Dry Creek Joint Elementary School District et al

Filing 48

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 4/18/17 ORDERING that the parties have until 5/18/2017 to meet and confer as required by FRCP 26(f) regarding their discovery plan as indicated in the Court's Initial Pretrial Scheduling Order (ECF No. 4 ). (Mena-Sanchez, L)

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IRWIN M. ZALKIN, ESQ. (#89957)
DEVIN M. STOREY, ESQ. (#234271)
ALEXANDER S. ZALKIN, ESQ. (#280813)
RYAN M. COHEN, ESQ. (#261313)
JACQUELINE J. MCQUARRIE, ESQ. (#267319)
The Zalkin Law Firm, P.C.
12555 High Bluff Drive, Suite 301
San Diego, CA 92130
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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A.T., a minor, by and through his Guardian
ad Litem L.T.,

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Plaintiff,

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v.

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DRY CREEK JOINT ELEMENTARY
SCHOOL DISTRICT, PLACER COUNTY
OFFICE OF EDUCATION, PLACER
COUNTY CHILDREN SYSTEM OF
CARE, and the following individuals, who
are named in their individual capacities:
KD ASHTON, BECKY BRAVO, PETER
BALDO, LIZ LEE, CINDY STONE,
RENEE VERDUGO, MARY BOEHM,
CHRISTY CARTER, WENDY DEVORE,
DONNA KEARNS, LISA HEWITT,
TAMMY PETERSON, STEPHANIE
DILBECK, JEN ROGERS, VALERIE
MILLER, DAVID MOUL, DEBBIE
CANNON, JUDY BENNEY, REBECCA
RATEKIN, CARLEY ROSE JACKSON,
LAURI MCNALLY, SANDRA MOORE,
and DOES 1-30,

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Defendants.

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Civil Action No: 2:16-cv-02925-MCE-DB
JOINT STIPULATION AND ORDER
REGARDING EXTENSION OF TIME
FOR RULE 26(F) DISCOVERY PLAN
MEET AND CONFER AND WRITTEN
REPORT

[Demand for Jury Trial]

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME FOR RULE 26(F)
DISCOVERY PLAN MEET AND CONFER AND WRITTEN REPORT

IT IS HEREBY STIPULATED, that the parties will have until after the hearing on

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Defendants’ Motions to Dismiss, calendared for May 4, 2017 to meet and confer pursuant to

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Federal Rule of Civil Procedure 26(f) and submit a written report. Pursuant to the Court’s

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Initial Pretrial Scheduling Order, the parties met and conferred on March 27, 2017. During that

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meeting, the parties discussed several issues including an appropriate protective order, notice

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correspondence pursuant to Federal Educational Rights and Privacy Act (FERPA), and a date

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for Initial Disclosures. Subsequently, considering the amount of parties and that several parties

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only recently appeared in the case, the parties agree that waiting to hold a Rule 26(f) conference

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until within fourteen (14) days after the passing of the May 4, 2017 hearing date, to May 18,

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2017, would be prudent.

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Dated: April 11, 2017

THE ZALKIN LAW FIRM

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_/s/ Ryan M. Cohen____________________
IRWIN M. ZALKIN
DEVIN M. STOREY
ALEXANDER S. ZALKIN
RYAN M. COHEN
JACQUELINE J. MCQUARRIE
Attorneys for Plaintiff
A.T., a minor, by and through his Guardian Ad Litem,
L.T.

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Respectfully submitted,

Dated:

LOZANO SMITH
____________________________________________
SLOAN R. SIMMONS
KRISTY J. BOYES
Attorneys for Defendants
DRY CREEK ELEMENTARY SCHOOL DISTRICT,
PLACER COUNTY OFFICE OF EDUCATION, PETER
BALDO, JUDY BENNEY, MARY BOEHM, BECKY
BRAVO, DEBBIE CANNON, STEPHANIE DILLBECK,
LISA HEWITT, LIZ LEE, VALERIE MILLER,
SANDRA MOORE, CYNDI STONE, KD ASHTON,
CHRISTY CARTER,WENDY DEVORE, DONNA
KEARNS and JEN ROGERS

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME FOR RULE 26(F)
DISCOVERY PLAN MEET AND CONFER AND WRITTEN REPORT

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Dated:

PLACER COUNTY COUNSEL’S OFFICE
____________________________________________
JULIA M. REEVES
Attorneys for Defendants
PLACER COUNTY CHILDREN’S SYSTEM OF CARE,
RENEE VERDUGO, DAVID MOUL, LAURI
MCNALLY, CARLEY ROSE JACKSON, TAMMY
PETERSON and REBECCA RATEKIN

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME FOR RULE 26(F)
DISCOVERY PLAN MEET AND CONFER AND WRITTEN REPORT

ORDER

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Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY

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ORDERED that the parties have until May 18, 2017 to meet and confer as required by Federal

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Rule of Civil Procedure 26(f) regarding their discovery plan as indicated in the Court’s Initial

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Pretrial Scheduling Order (ECF No. 4).

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IT IS SO ORDERED.
Dated: April 18, 2017

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME FOR RULE 26(F)
DISCOVERY PLAN MEET AND CONFER AND WRITTEN REPORT