Jensen et al v. County of Sonoma

Filing 43

STIPULATION AND ORDER STAYING COURT PROCEEDINGS AND CONTINUING CASE MANAGEMENT CONFERENCE OF 7/31/9. Further Case Management Conference re-set for 9/18/2009 at 01:30 PM. Signed by Judge Joseph C. Spero on 07/09/09. (klh, COURT STAFF) (Filed on 7/9/2009)

Case3:08-cv-03440-JCS Document42

Filed07/02/09 Page1 of 2

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
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 AND CONTINUING CASE MANAGEMENT CONFERENCE OF 7/31/09; 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

met again for further settlement conference on June 18, 2009. As a result, the parties have agreed to jointly seek a request that the Court continue to stay the court proceedings in light of the parties' agreement to further continue the Mandatory Settlement Conference with Magistrate Zimmerman to August 14, 2009 at 9:00 a.m., a date confirmed by Magistrate Zimmerman by order filed June 19, 2009; 2. The parties agree to stay all pending discovery (not to re-open discovery), including

expert discovery; 3. The parties jointly request that the currently scheduled Case Management Conference of

July 31, 2009, at 1:30 p.m. be continued to a date within 30 days after the continued settlement
NO. CV 08-3440 JCS: STIPULATION AND ORDER STAYING COURT PROCEEDINGS/ORDER THEREON 1

Case3:08-cv-03440-JCS Document42

Filed07/02/09 Page2 of 2

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
SENNEFF FREEMAN BLUESTONE

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:

July 2, 2009

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

DATED:

July 2, 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 proceedings and all discovery are stayed, pending the continued Mandatory Settlement Conference scheduled for August 14, 2009. The currently scheduled Case Management Conference of July 31, 2009 is VACATED. In the event that a dismissal of the case is not filed following the continued settlement conference, the case will be set for further Case Management Conference/Trial Setting Conference on ___________S_pte__ber 18__________, 2009. The parties shall submit a joint Case Management _ e __ m _____ Statement 7 days prior to the conference.
UNIT ED
ISTRIC ES D TC AT T

RT U O

ER

N

F D IS T IC T O R

NO. CV 08-3440 JCS:

STIPULATION AND ORDER STAYING COURT PROCEEDINGS/ORDER THEREON

A

C

LI

FO

R NIA

DATED:

7/9/09 ________________

_____________________________________ JOSEPH C. SPERO United Statesudge Joseph C. SperJudge Magistrate o J
NO

S

RT

H

2