City of Lincoln v. County of Placer

Filing 36

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 12/06/21 re Document Authentication. (Benson, A.)

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Kristine L. Mollenkopf (SBN No. 185914)
[e-mail]
City Attorney
City of Lincoln, City Attorney’s Office
600 Sixth Street
Lincoln, CA 95648
Tel: [phone]/Fax: [phone]

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William D. Brown (SBN No. 125468)
[e-mail]
Jeffrey T. Orrell (SBN No. 237581)
[e-mail]
Janet Menacher (SBN No. 291365)
[e-mail]
Charles D. Grosenick (SBN 317715)
[e-mail]
2533 S. Coast Highway 101, Suite 270
Cardiff-by-the-Sea, CA 92007-1737
Tel: [phone]/Fax: [phone]

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Attorneys for Plaintiff/Counter-Defendant CITY OF LINCOLN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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)
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Plaintiff/Counter-Defendant
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v.
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COUNTY OF PLACER; and DOES 1 through )
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100, inclusive,
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Defendant/Counterclaimant.
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CITY OF LINCOLN,

Case No.: 2:18-CV-00087-KJM-AC
FIRST AMENDED JOINT
STIPULATION AND [PROPOSED]
ORDER REGARDING DOCUMENT
AUTHENTICATION

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______________________________________________________________________________
00049026.1

FIRST AMENDED JOINT STIPULATION AND [PROPOSED] ORDER
RE DOCUMENT AUTHENTICATION
2:18-cv-00087-KJM-AC

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The parties to the above-captioned action, Plaintiff/Counter-Defendant City of Lincoln (“City”)

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and Defendant/Counterclaimant County of Placer (“County”) (hereinafter collectively, the “Parties”),

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have met and conferred regarding the goal of streamlining the presentation of evidence at trial and

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preserving judicial and litigation resources. The Parties have agreed and hereby stipulate to the specific

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terms set forth below, and respectfully request that the Court ratify and enter an Order as follows:

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1.

The Parties agree to not dispute the authenticity of the documents identified by
“Bates” numbers and enumerated in the attached Exhibit 1.

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That a document is stipulated to as authentic in Exhibit 1 does not waive either
Party’s ability to object to the admission of the document into evidence on grounds
of relevance, hearsay-within-hearsay, or any other lawful objection.

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The Parties further stipulate to undertake a good faith effort to supplement the list
of documents whose authenticity the Parties agree to not dispute.

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The Parties intend that this First Amended Joint Stipulation and [Proposed] Order
Regarding Document Authentication (hereinafter, “Amended Joint Stipulation”)
supersede and replace the Joint Stipulation and Order Regarding Document
Authentication, signed by the Court on 2 October 2020 (attached hereto, as Exhibit
2). The Parties further intend that all documents previously listed in Exhibit 2 have
been incorporated into this Amended Joint Stipulation, for efficiency and ease of
reference, as shown within Exhibit 1.

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SO STIPULATED.
Dated: December 3, 2021

BROWN & WINTERS

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By: /s/ Charles D. Grosenick
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CHARLES D. GROSENICK
Attorneys for Plaintiff and Counter-Defendant
CITY OF LINCOLN

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Dated: December 1, 2021

HARTMAN KING PC

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By: /s/Alanna Lungren
JENNIFER HARTMAN KING
ALANNA LUNGREN
J. R. PARKER
ANDREYA WOO NAZAL
Attorneys for Defendant and
Counter-Claimant COUNTY OF PLACER

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______________________________________________________________________________
00049026.1

FIRST AMENDED JOINT STIPULATION AND [PROPOSED] ORDER
RE DOCUMENT AUTHENTICATION
2:18-cv-00087-KJM-AC

ORDER

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Pursuant to the above stipulation of the Parties:

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IT IS SO ORDERED.

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Dated: December 6, 2021

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______________________________________________________________________________
00049026.1

FIRST AMENDED JOINT STIPULATION AND [PROPOSED] ORDER
RE DOCUMENT AUTHENTICATION
2:18-cv-00087-KJM-AC