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

Filing 327

STIPULATION AND ORDER re 325 filed by Bill Cogbill, County of Sonoma, Sonoma County Sherrif's Department. Signed by Judge Elizabeth D. Laporte on 7/26/2010. (lmh, COURT STAFF) (Filed on 7/26/2010)

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George et al v. Sonoma County Sherrif's Department et al Doc. 327 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Gregory G. Spaulding, Esq. (SB# 106606) Terry S. Sterling, Esq. (SB# 106379) SPAULDING McCULLOUGH & TANSIL LLP 90 South E Street, Suite 200 P.O. Box 1867 Santa Rosa, CA 95402 Telephone: (707) 524-1900 / Facsimile: (707) 524-1906 spaulding@smlaw.com; sterling@smlaw.com Attorneys for Defendants SONOMA COUNTY SHERIFF'S DEPARTMENT, BILL COGBILL and COUNTY OF SONOMA UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA VALERIE GEORGE, as Administrator and Personal Representative of THE ESTATE OF RYAN GEORGE; VALERIE GEORGE and TAJMAH BEAUCHAMP, as Legal Representatives 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.; and DOES 1 through 25, inclusive, Defendants. Case No.: 3:08-cv-02675-EDL STIPULATION AND [PROPOSED] ORDER ALLOWING DEFENDANTS COUNTY OF SONOMA, SONOMA COUNTY SHERIFF'S DEPARTMENT AND BILL COGBILL TO FILE MEMORANDA OF POINTS AND AUTHORITIES IN EXCESS OF 25 PAGES IN LENGTH Hon. Elizabeth D. Laporte Defendants COUNTY OF SONOMA, SONOMA COUNTY SHERIFF'S DEPARTMENT and BILL COGBILL intend to file two Motions for Summary Judgment or, in the Alternative, Partial Summary Judgment (one Motion will be filed by COUNTY OF SONOMA and SONOMA COUNTY SHERIFF'S DEPARTMENT (collectively, "the COUNTY") and a separate Motion will 1 STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 be filed by BILL COGBILL). Plaintiffs allege ten causes of action against the COUNTY and fourteen causes of action against COGBILL. It is anticipated that the Memorandum of Points and Authorities that will be filed in support of each of the two Motions will exceed the 25 pages allowed by Local Rules 7-2(b) and 7-4(b). This additional space is necessary to fully argue the complex issues presented by the Third Amended Complaint. COUNTY and COGBILL cannot provide the Court with a full analysis of the issues subject to summary judgment or partial summary judgment, including a complete analysis of the law and facts pertaining thereto, in 25 pages. Defendants require additional space, of up to 10 additional pages for each of the two Memoranda that will be filed in support of two Motions. Therefore, pursuant to Local Rule 7-12: IT IS HEREBY STIPULATED AND AGREED by and among the undersigned counsel that, subject to the Court's approval, the COUNTY and COGBILL may each file a Memorandum of Points and Authorities in support of their two separate Motions for Summary Judgment or, in the Alternative, Partial Summary Judgment (one Motion to be filed by the COUNTY and one Motion to be filed by COGBILL) of up to 35 pages in length. DATED: July 23, 2010 SANFORD, WITTELS & HEISLER LLP Attorneys for Plaintiffs By: /s/ Steven L. Wittels, Esq. DATED: July 23, 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. 2 STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: July 23, 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. DATED: July 23, 2010 HASSARD BONNINGTON LLP Attorneys for Defendants JOSEPH N. MATEL, M.D. and RICHARD FLINDERS, M.D. By: /s/ Joanna L. Storey, Esq. DATED: July 23, 2010 LAFOLLETTE, JOHNSON, DEHAAS, FESLER & AMES Attorneys for Defendant SUTTER MEDICAL CENTER OF SANTA ROSA By: /s/ Larry Byron Thornton DATED: July 23, 2010 ROGASKI, PREOVOLOS, WEBER & PATTERSON, LLP Attorneys for Defendant NORICK JANIAN, M.D. By: /s/ Chester A. Rogaski, Jr., Esq. 3 STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FILER'S ATTESTATION Pursuant to General Order 45, section X.B regarding signatures, I hereby attest under penalty of perjury that concurrence in the filing of the document has been obtained for any signatures indicated by a "conformed" signature (/s/) within this e-filed document. DATED: July 23, 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. 4 STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 1 2 3 4 5 6 7 8 9 [PROPOSED] ORDER Based on the foregoing Stipulation, and good cause appearing therefore, IT IS HEREBY ORDERED: Defendants COUNTY OF SONOMA and SONOMA COUNTY SHERIFF'S DEPARTMENT (collectively, "the COUNTY"), and BILL COGBILL may each file a Memoranda of Points and Authorities in support of their separate Motions for Summary Judgment or, in the Alternative, Partial Summary Judgment (one Motion to be filed by the COUNTY and one Motion to be filed by COGBILL) of up to 35 pages in length. 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 ER N F D IS T IC T O R STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL A C LI FO D. izabeth udge El J Laporte R NIA ELIZABETH D. LAPORTE ED ER United States S SO ORD I Magistrate Judge UNIT ED 10 Dated: July 26 , 2010__________ S S DISTRICT TE C TA RT U O IT NO RT H

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