Jensen et al v. County of Sonoma

Filing 39

STIPULATION AND ORDER STAYING COURT PROCEEDINGS. All dates in the Court's Order of November 17, 2008 are VACATED. Further Case Management Conference set for 7/31/2009 at 01:30 PM. Signed by Judge Joseph C. Spero on 3/16/09. (klh, COURT STAFF) (Filed on 3/16/2009)

Case 3:08-cv-03440-JCS

Document 38

Filed 03/13/2009

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SENNEFF FREEMAN BLUESTONE

Bonnie A. Freeman, Esq. (SB 180502) SENNEFF FREEMAN & BLUESTONE, LLP 50 Old Courthouse Square, Suite 401 P.O. Box 3729 Santa Rosa, CA 95402-3729 Telephone: [phone] Facsimile: 707-526-0347 Attorneys for Defendant County of Sonoma

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ROSEMARY JENSEN AND RANDY JENSEN, Plaintiffs, v. COUNTY OF SONOMA, Defendant. / No. CV 08 3440 JCS (BZ) STIPULATION AND ORDER STAYING COURT PROCEEDINGS; PROPOSED ORDER THEREON

Defendant County of Sonoma and Plaintiffs Rosemary Jensen and Randy Jensen, having participated in the Mandatory Settlement Conference before Hon. Bernard Zimmerman, make the following stipulations and request an Order from the Court as follows: 1. The parties participated in good faith in the settlement conference on March 5, 2009, and

have agreed to jointly seek a request that the Court stay the court proceedings as scheduled in this Court's Order of November 17, 2008, and specifically seek that the Court vacate that order and the following appearances and deadlines contained within that Order: A. B. C. D. E. Trial date of August 31, 2009; Discovery completion date of March 1, 2009; Expert disclosures made by May 30, 2009; Hearing on dispositive motions on May 1, 2009; Pretrial Conference date of August 21, 2009.

NO. CV 08-3440 JCS:

STIPULATION AND ORDER STAYING COURT PROCEEDINGS/ORDER THEREON

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Case 3:08-cv-03440-JCS

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Filed 03/13/2009

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SENNEFF FREEMAN BLUESTONE

2.

The parties have agreed to continue the Mandatory Settlement Conference with

Magistrate Zimmerman to June 25, 2009 at 9:00 a.m., a date confirmed by Magistrate Zimmerman by order filed March 5, 2009; 3. The parties agree to stay all pending discovery (not to re-open discovery), including

expert discovery; 4. The parties jointly request that a Case Management Conference with the Court be

scheduled within 30 days after the continued settlement conference, the purpose of which would be to update the court with the parties' efforts at resolution and/or, alternatively, to obtain an updated pre-trial order from the Court. The parties would submit a Joint Case Management Conference statement 7 days' prior to the Case Management Conference.

DATED:

March 13, 2009

SENNEFF FREEMAN & BLUESTONE, LLP By: /s/ Bonnie A. Freeman---------------------------------Bonnie A. Freeman Attorneys for Defendant County of Sonoma

DATED:

March 13, 2009

/s/ Frear Stephen Schmid--------------------------Frear Stephen Schmid, Attorney for Plaintiffs

ORDER Good cause appearing, and pursuant to the stipulation above, IT IS HEREBY ORDERED that the Court's Order of November 17, 2008, is hereby VACATED and the court proceedings and all discovery are stayed, pending the continued Mandatory Settlement Conference scheduled for June 25, 2009. In the event that a dismissal of the case is not filed following the settlement conference, the case will be set for further Case Management July 31 Conference/Trial Setting Conference on ________________________________, 2009. The parties shall submit a joint Case Management Statement 7 days prior to the conference.
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NO. CV 08-3440 JCS:

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DATED:

March 16, 2009 ________________

_____________________________________ JOSEPH C. SPERO o United States MagistrateerJudge h C. Sp ge Josep
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