Baker v. County of Sonoma et al

Filing 36

STIPULATION AND ORDER RE CASE DEADLINES: Defendants' Motion to Dismiss First Amended Complaint 30 and Initial Case Management Conference are continued to 1/27/2009 02:00 PM. Signed by Judge Elizabeth D. Laporte on 11/18/08. (lmh, COURT STAFF) (Filed on 11/18/2008)

Thomas Marc Litton (CA Bar # 119985) SANFORD WITTELS & HEISLER, LLP 120 Montgomery Street, Suite 1600 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Steven L. Wittels SANFORD WITTELS & HEISLER, LLP 950 Third Avenue, 10th Floor New York, New York 10022 Telephone: [phone] Facsimile: [phone] [e-mail] Pending Pro Hac Vice Admission Attorneys for Plaintiff Eric Baker UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ERIC JAMES BAKER, Plaintiff, vs. COUNTY OF SONOMA; SONOMA COUNTY SHERIFF'S DEPARTMENT; BILL COGBILL; CALIFORNIA FORENSIC MEDICAL GROUP, INC.; JAMES LUDERS, M.D.; LEWIS LINCOLN; DANIEL CORTEZ; EDUARDO ESPINO; and DOES 1 through 10, inclusive, Defendants. Case No. 3:08-cv-03433-EDL ECF Case

STIPULATION AND [PROPOSED]
ORDER RE CASE DEADLINES Hon. Elizabeth Laporte

IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel for all parties, that subject to the Court's approval, the return date and briefing

schedule on the following motion of the parties, and initial Case Management Conference, shall be as follows: I. County Defendants' Motion to Dismiss

1. Plaintiff's response to the motion to dismiss filed by Defendants County of Sonoma, Sonoma County Sheriff's Department, Bill Cogbill, Lewis Lincoln, Daniel Cortez, and Eduardo Espino (the "County Defendants") shall be served by December 30, 2008. 2. The County Defendants' reply in support of their 12b(6) motion to dismiss shall be served by January 13, 2008. 3. The Return Date and Hearing on County Defendants' 12b(6) motion to dismiss 2:00pm are adjourned until January 27, 2008 at 9:00 a.m. before the Honorable Elizabeth D. Laporte. II. Initial Case Management Conference

1. The Initial Case Management Conference scheduled for December 16, 2008 is adjourned until January 27, 2008, directly following the hearing on Defendants' Motions to Dismiss scheduled for January 27, 2008. 2. The Joint Case Management Statement will be due one week prior to the adjourned conference date, on January 20, 2008.

The reason for these requests is that Plaintiff's counsel is currently in the midst of briefing multiple cases under prior court Orders, and requires this additional time to respond to Defendants' 12(b)(6) motion.

Date: November 17, 2008 Respectfully submitted, SANFORD WITTELS & HEISLER, LLP By: ______/s/______________________ Thomas Marc Litton (CA Bar # 119985) Of Counsel 120 Montgomery Street, Suite 1600 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] SANFORD WITTELS & HEISLER, LLP By: _______/s/_______________________ Steven L. Wittels (SLW-8110) 950 Third Ave, 10th Floor New York, New York 10022 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiffs

TRIMBLE SHERINIAN & VARANINI By:_______/s/_______________________ Jerome M. Varanini 2500 Ventura Oaks Way, Suite 350 (95833) P.O. Box 590 Sacramento, CA 95812-0590 Telephone: [phone] Attorneys for Defendants California Forensic Medical Group and James Luders, M.D.

\ SENNEFF FREEMAN & BLUESTONE, LLP By:______/s/________________________ Bonnie A. Freeman 50 Old Courthouse Square, Ste 401 P.O. Box 3729 Santa Rosa, CA 95402 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants County of Sonoma, Sonoma County Sheriff's Department, Bill Cogbill, Lewis Lincoln, Daniel Cortez, and Eduardo Espino

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