Olfati v. County of Sacramento et al

Filing 35

ORDER signed by Chief District Judge Kimberly J. Mueller on 05/31/2024 GRANTING 32 Motion for Extension of Time and EXTENDING the deadline to hear the Dispositive Motions from 08/09/2024 to 11/29/2024 at 10:00 AM in Courtroom 3 (KJM) before Chief District Judge Kimberly J. Mueller. (Nair, C)

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STEVEN MARK KAMP (California State Bar Number 116817)
STEVEN KAMP LAW OFFICE, 22 Petrilli Circle, Sacramento, CA 95822
Electronic Mail Address: [e-mail]
Telephone: [phone] (cellular, voice/text)
Attorney for Plaintiff Ms. Parvin Olfati

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PORTER SCOTT, A PROFESSIONAL CORPORATION
Carl L. Fessenden, SBN 161494
[e-mail]
Suli A. Mastorakos, SBN 330383
[e-mail]
2180 Harvard Street, Suite 500
Sacramento, California 95815
TEL: [phone]
FAX: [phone]

Attorneys for Defendants
COUNTY OF SACRAMENTO, PAMELA PISANI, JENNIFER REIMAN, JENNIFER
STEWART, and SHERIFF’S SERGEANT RONALD BRIGGS
Exempt from Filing Fees Pursuant to Government Code § 6103

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Ms. PARVIN OLFATI, Plaintiff,
v.
COUNTY OF SACRAMENTO et al.,
Defendants.

No. 2:22-CV-01127-KJM-JDP
JOINT MOTION TO MODIFY ECF 23
SCHEDULING ORDER TO EXTEND
DISPOSITIVE MOTION HEARING
DEADLINE FROM 2024 AUGUST 9 TO
2024 NOVEMBER 29
Hearing Date: July 12, 2024

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Hearing Time: 10:00 a.m.

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Courtroom: 3, 15th floor

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Judge: Hon. Kimberley J. Mueller

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Pursuant to Federal Rules of Civil Procedure Rule 16(b)(4) (“Rule”) and Eastern District of

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California Local Rule (“L.R.”) 230, Plaintiff Ms. Parvin Olfati (“Plaintiff”) and Defendants County

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of Sacramento, Pamela Pisani, Jennifer Reiman, Jennifer Stewart and Sheriff’s Sergeant Ronald
JOINT MOTION OF PLAINTIFF AND COUNTY OF SACRAMENTO DEFENDANTS TO MOVE
THE ECF 23 DISPOSITIVE MOTION HEARING DEADLINE FROM 2024 AUGUST 9 TO 2024
NOVEMBER 29 page 1

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Briggs (“County Defendants”) hereby jointly move the Court to modify the ECF 23 Scheduling

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Conference Minutes order to move the disposition motion hearing deadline from August 9, 2024 to

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November 29, 2024.

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Good cause under Rule 16(b)(4) exists for this Motion, as follows:
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The parties in this action (Plaintiff and the County Defendants) are currently

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involved in meet and confer regarding various responses by County Defendants to Plaintiff’s written

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discovery requests. The parties are attempting to resolve all disputes by the June 17, 2024, discovery

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deadline. Under the list of available civil hearing dates on the Court’s website, the available hearing

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date closest to August 9 is August 2; under the 35-day clock in L.R. 230, motions and supporting

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papers would need to be filed on June 27, 2024, ten days after the discovery cut-off date.
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Also, Plaintiff has filed a California Public Records Act (CPRA) Petition for Writ

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of Mandate against the County of Sacramento in the Superior Court of California, County of

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Sacramento, Case No. 34-2021-00310164, Parvin Olfati vs. County of Sacramento et al. The matter

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is set for hearing on June 10, 2024. There is extensive briefing related to the writ petition, which

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the parties are currently engaged in. The briefing is anticipated to conclude on or about May 28,

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2024. In addition, Petitioner Ms. Olfati has additional CPRA Requests that she and the County

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Respondents are discussing including in a second hearing after June 10, 2024.

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3.

Further, Defendants’ counsel will be out of the United States on pre-paid vacations

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during June 7-24, 2024, and during July 5-25, 2024, respectively. In addition, County Defendants’

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counsel have a trial scheduled to start the first week of August.

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4.

Plaintiff through her undersigned counsel has the following matters pending in this

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Court other than this action, or in the Sacramento County Superior Court (other than the above-

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mentioned 34-2021-00310164):

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(a) E.D. Cal. Case No. 2:21-cv-00606 CKD, Parvin Olfati vs. City of Sacramento et

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al., partial summary judgment in favor of Plaintiff on March 27, 2024 in ECF 209;

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pre-trial conference and trial expected.

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JOINT MOTION OF PLAINTIFF AND COUNTY OF SACRAMENTO DEFENDANTS TO MOVE
THE ECF 23 DISPOSITIVE MOTION HEARING DEADLINE FROM 2024 AUGUST 9 TO 2024
NOVEMBER 29 page 2

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(b) E.D.Cal.Case No. 2:23-cv-02547 JDP, Parvin Olfati vs. City of Sacramento et

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al., filed November 6, 2023; City of Sacramento has answered the Complaint; four

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Conspirator Defendants have filed Rule 12(b)(6) motions not yet ruled upon .

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(c) Sacramento County Superior Court Case 23WM000031, Parvin Olfati vs. City

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of Sacramento et al. – May 24, 2024 hearings on prevailing party Petitioner’s

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motion for attorney’s fees and motion for supplemental writ of mandate.

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(d) July 12, 2024 Sacramento County Superior Court hearings on:

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(i) Steven Maviglio vs. Parvin Olfati, Case No. 34-2019-70006336

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(ii) Thomas Jameson O’Brien vs. Parvin Olfati, Case No. 23CH001493

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(iii) Thomas James O’Brien vs. Parvin Olfati, Case No. 24CH000169

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(iv) Parvin Olfati vs. Thomas James O’Brien, Case No. 24CH000378

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Accordingly, the parties respectfully request that the Court extend the dispositive motion

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filing deadline by 112 calendar days from the ECF 23 date of August 9, 2024 to November 29,

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2024, in order to provide the parties sufficient time to prepare their respective dispositive motions

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and supporting documents, which are anticipated to be extensive in light of the number of claims

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asserted by Plaintiff in this lawsuit, and the County Defendants’ defenses.

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Respectfully submitted May 10, 2024, by:

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/s/
May 9, 2024 by Steven Mark Kamp, Attorney for Plaintiff Ms. Parvin Olfati
State Bar of California Number 116817; Steven Kamp Law Office, 22 Petrilli Circle, Sacramento,
California 95822 Electronic mail address: [e-mail] Telephone: [phone]
(cellular, voice/text)

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/s/ Suli Mastorakos, Esq. (Authorized on 5/10/2024)

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/s/ Carl Fessenden, Esq. (Authorized on 5/10/2024)

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PORTER SCOTT APC, 2180 Harvard Street, Suite 500, Sacramento, CA 95815
Attorneys for Defendants
COUNTY OF SACRAMENTO, PAMELA PISANI, JENNIFER REIMAN, JENNIFER
STEWART, and SHERIFF’S SERGEANT RONALD BRIGGS
JOINT MOTION OF PLAINTIFF AND COUNTY OF SACRAMENTO DEFENDANTS TO MOVE
THE ECF 23 DISPOSITIVE MOTION HEARING DEADLINE FROM 2024 AUGUST 9 TO 2024
NOVEMBER 29 page 3

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ORDER
Good cause appearing and pursuant to the parties’ joint motion, the court extends the

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IT IS SO ORDERED.
DATED: May 31, 2024.

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JOINT MOTION OF PLAINTIFF AND COUNTY OF SACRAMENTO DEFENDANTS TO MOVE
THE ECF 23 DISPOSITIVE MOTION HEARING DEADLINE FROM 2024 AUGUST 9 TO 2024
NOVEMBER 29 page 4