Estate of Tyler S. Rushing et al v. AG Private Protection, Inc. et al

Filing 34

ORDER signed by District Judge Morrison C. England, Jr on 11/13/19 ORDERING that County Defendants be allowed to up to twenty-seven (27) pages for their Memorandum of Points and Authorities in Support of Motion for Summary Judgment or, in the Alternative, Partial Summary Judgment. Any opposition to said motion may also be up to twenty-seven (27) pages in length; and Any reply shall not exceed fifteen (15) pages. (Mena-Sanchez, L)

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A PROFESSIONAL CORPORATION
Stephen E. Horan, SBN 125241
William E. Camy, SBN 291397
350 University Avenue, Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]
OFFICE OF COUNTY COUNSEL
COUNTY OF BUTTE
Bruce S. Alpert, SBN 075684
Brad J. Stephens, SBN 212246
25 County Center Drive
Oroville, CA 95965
TEL: [phone]
FAX: [phone]
Attorneys for Defendants COUNTY OF BUTTE, BUTTE COUNTY SHERIFF’S OFFICE, and DEPUTY
SHERIFF IAN DICKERSON
Exempt from Filing Fees Pursuant to Government Code § 6103

PORTER | SCOTT

350 University Ave., Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT

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ESTATE OF TYLER S. RUSHING, SCOTT
K. RUSHING, and PAULA L. RUSHING
Plaintiffs,

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v.
AG PRIVATE PROTECTION, INC., EDGAR
SANCHEZ, CITY OF CHICO, CHICO
POLICE DEPARTMENT, SCOTT RUPPEL,
CEDRIC SCHWYZER, ALEZ FLIEHR,
JEREMY GAGNEBIN, COUNTY OF
BUTTE, BUTTE COUNTY SHERIFF’S
OFFICE, IAN DICKERSON, and DOES 1 to
20,

CASE NO.: 2:18-cv-01692-MCE-AC
DEFENDANTS COUNTY OF BUTTE,
BUTTE COUNTY SHERIFF’S OFFICE,
AND IAN DICKERSON’S REQUEST TO
EXTEND
PAGE
LIMIT
FOR
DEFENDANTS’
MEMORANDUM
OF
POINTS AND AUTHORITIES IN SUPPORT
OF
MOTION
FOR
SUMMARY
JUDGMENT OR, IN THE ALTERNATIVE,
PARTIAL
SUMMARY
JUDGMENT;
ORDER

Complaint filed: 06/08/18
Defendants.
______________________________________/

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{02100439.DOCX}

DEFENDANTS COUNTY OF BUTTE, BUTTE COUNTY SHERIFF’S OFFICE, AND IAN DICKERSON’S
REQUEST TO EXTEND PAGE LIMIT FOR DEFENDANTS’ MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
PARTIAL SUMMARY JUDGMENT; ORDER

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TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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Defendants COUNTY OF BUTTE, BUTTE COUNTY SHERIFF’S OFFICE, and IAN

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DICKERSON (“County Defendants”) respectfully request permission from this Court to file a

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Memorandum of Points and Authorities in Support of Motion for Summary Judgment or, in the

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Alternative, Partial Summary Judgment in excess of the twenty-page limit as contained in the Court’s

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Standing Orders.

comply with the page limitation as set forth above, and have made every effort to eliminate

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extraneous arguments from their Memorandum, but it has become apparent that County Defendants

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cannot properly address each of the issues in its memorandum within the twenty-page limitation

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given the complex issues involved in this case, and that Plaintiff alleges eight claims for relief and

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PORTER | SCOTT

In support of this request, County Defendants state that they have attempted in good faith to

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350 University Ave., Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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numerous allegations in support of those claims.

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WHEREFORE, County Defendants respectfully request that:

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1. County Defendants be allowed to up to twenty-seven (27) pages for their Memorandum of

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Points and Authorities in Support of Motion for Summary Judgment or, in the Alternative, Partial

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Summary Judgment.

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2. Any opposition to said motion may also be up to twenty-seven (27) pages in length; and

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3. Any reply shall not exceed fifteen (15) pages.

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Dated: July 26, 2016

Respectfully submitted,
PORTER SCOTT

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A PROFESSIONAL CORPORATION

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By

/s/ Stephen E. Horan
Stephen E. Horan
William E. Camy
Attorney for Defendants COUNTY OF
BUTTE, BUTTE COUNTY SHERIFF’S
OFFICE, and IAN DICKERSON

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{02100439.DOCX}

DEFENDANTS COUNTY OF BUTTE, BUTTE COUNTY SHERIFF’S OFFICE, AND IAN DICKERSON’S
REQUEST TO EXTEND PAGE LIMIT FOR DEFENDANTS’ MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
PARTIAL SUMMARY JUDGMENT; ORDER

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GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that:

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1. County Defendants be allowed to up to twenty-seven (27) pages for their Memorandum

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of Points and Authorities in Support of Motion for Summary Judgment or, in the Alternative,

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Partial Summary Judgment.

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2. Any opposition to said motion may also be up to twenty-seven (27) pages in length; and

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3. Any reply shall not exceed fifteen (15) pages.

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IT IS SO ORDERED.

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DATED: November 13, 2019

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_______________________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE

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PORTER | SCOTT

350 University Ave., Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

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{02100439.DOCX}

DEFENDANTS COUNTY OF BUTTE, BUTTE COUNTY SHERIFF’S OFFICE, AND IAN DICKERSON’S
REQUEST TO EXTEND PAGE LIMIT FOR DEFENDANTS’ MEMORANDUM OF POINTS AND
AUTHORITIES IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT OR, IN THE ALTERNATIVE,
PARTIAL SUMMARY JUDGMENT; ORDER