George et al v. Sonoma County Sherrif's Department et al

Filing 266

STIPULATION AND ORDER AS MODIFIED re #264 Stipulation filed by Tajmah Beauchamp, Valerie George, Donald George. Signed by Magistrate Judge Elizabeth D. Laporte on February 8, 2010. (edllc2, COURT STAFF) (Filed on 2/9/2010)

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Thomas Marc Litton (CA Bar # 119985) SANFORD WITTELS & HEISLER, LLP 555 Montgomery Street, Suite 820 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Steven L. Wittels SANFORD WITTELS & HEISLER, LLP 1350 Avenue of the Americas, 31st Floor New York, NY 10019 Telephone: [phone] Facsimile: [phone] [e-mail] Admitted Pro Hac Vice

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA VALERIE GEORGE, as Administrator and Personal Representative of THE ESTATE OF RYAN GEORGE; VALERIE GEORGE and/or TAJMAH BEAUCHAMP, as Legal Representative(s) for Jaida George and Ryan George, Jr.; VALERIE GEORGE, Individually; DONALD GEORGE; and TAJMAH BEAUCHAMP, Individually, Plaintiffs, vs. SONOMA COUNTY SHERIFF'S DEPARTMENT; BILL COGBILL; COUNTY OF SONOMA; CALIFORNIA FORENSIC MEDICAL GROUP, INC; JAMES LUDERS, M.D.; MICHAEL E. DAGEY, R.N.; SUTTER HEALTH; SUTTER MEDICAL CENTER OF SANTA ROSA; EDWARD W. HARD, M.D.; RICHARD FLINDERS, M.D.; JOSEPH N. MATEL, M.D.; NORICK JANIAN, M.D.; ANGUS MATHESON, M.D., and DOES 1 through 25, inclusive, Defendants.

Case No. 3:08-cv-02675-EDL ECF Case

STIPULATION AND [PROPOSED] ORDER RE PRETRIAL CASE MANAGEMENT DEADLINES

JURY TRIAL DEMANDED

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IT IS HEREBY STIPULATED AND AGREED by and among the parties hereto, through their attorneys of record, that: (i) In order to avoid the expense and time of potentially unnecessary expert discovery and dispositive motion practice, and (ii) To facilitate the mediation scheduled for March 23, 2010,

subject to the Court's approval, the Order Following Further Case Management Conference dated November 18 2009 (Doc #226), is hereby amended as follows: 1. ALTERNATIVE DISPUTE RESOLUTION -- MEDIATION All parties have agreed to privately mediate this case and attend a full-day mediation scheduled before the Honorable Rebecca Westerfield (of JAMS) on March 23, 2010. 2. EXPERTS a. Plaintiffs shall disclose the names of their rebuttal experts by February 19, 2010; b. Rebuttal reports shall be produced by February 22, 2010; and c. All expert discovery, including depositions of experts, shall be completed no later than May 7, 2010. 3. MOTIONS a. The last day for hearing dispositive motions shall be June 15, 2010, 9:00a.m, without prejudice to motions being heard on an earlier date. 57 b. The parties agree to file their dispositive motions at least 50 days before the noticed hearing date.

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32 c. Responsive papers to dispositive motions shall be filed 25 days before the noticed hearing date. 21 d. Reply papers in support of dispositive motions shall be filed 14 days before the noticed hearing date. 4. TRIAL The trial date of September 7, 2010 which the Court set by Order dated December 3, 2009 (Doc #233) shall remain in effect. DATED: February 3, 2010 SANFORD, WITTELS & HEISLER, LLP Attorneys for Plaintiffs VALERIE GEORGE, TAJMAH BEAUCHAMP, and DONALD GEORGE By: /s/ Steven L. Wittels, Esq.

DATED: February 3, 2010

SPAULDING McCULLOUGH & TANSIL, LLP Attorneys for Defendants SONOMA COUNTY SHERIFF'S DEPARTMENT, BILL COGBILL and COUNTY OF SONOMA By: /s/ Terry S. Sterling, Esq.

DATED: February 3, 2010

TRIMBLE, SHERINIAN & VARANINI Attorneys for Defendants CALIFORNIA FORENSIC MEDICAL GROUP, INC.; JAMES LUDERS, M.D. and MICHAEL E. DAGEY, R.N. By: /s/ Jerome M. Varanini, Esq.

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DATED: February 3, 2010

LAFOLLETTE, JOHNSON, DEHAAS, FESLER & AMES Attorneys for Defendant SUTTER MEDICAL CENTER OF SANTA ROSA

By:

/s/ Larry Byron Thornton, Esq.

DATED: February 3, 2010

HASSARD BONNINGTON LLP Attorneys for Defendants JOSEPH N. MATEL, M.D. and RICHARD FLINDERS, M.D. By: /s/ Joanna L. Storey, Esq.

DATED: February 3, 2010

ROGASKI, PREOVOLOS, WEBER & PATTERSON, LLP Attorneys for Defendant NORICK JANIAN, M.D. By: /s/ Chester A. Rogaski, Jr., Esq.

Dated: February 8, 2010 SO ORDERED:______________________________ U.S.D.M.J.

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