Jensen et al v. County of Sonoma

Filing 47

STIPULATION AND ORDER STAYING COURT PROCEEDINGS AND CONTINUING CASE MANAGEMENT CONFERENCE. The Further Case Management Conference previously set for 9/18/9 is vacated and re- set for 11/6/2009 at 01:30 PM. Signed by Judge Joseph C. Spero on 8/26/09. (klh, COURT STAFF) (Filed on 8/27/2009)

Case3:08-cv-03440-JCS Document46

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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 AND CONTINUING CASE MANAGEMENT CONFERENCE OF 9/18/09; 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 jointly sought 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, which was to be held on August 14, 2009 at 9:00 a.m. However, plaintiff requested, and Judge Zimmerman granted, a continuance of that hearing until October 27, 2009 at 9:00 a.m. 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
STIPULATION AND ORDER STAYING COURT PROCEEDINGS/ORDER THEREON 1

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SENNEFF FREEMAN BLUESTONE

September 18, 2009, at 1:30 p.m. be continued to a date 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:

August 24, 2009

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

DATED:

August 24, 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 October 27, 2009. The currently scheduled Case Management Conference of September 18, 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 November 6, ________________________________, 2009. The parties shall submit a joint Case Management Statement 7 days prior to the conference. August 26, 2009 ________________
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_____________________________________ JOSEPH C. SPERO C. Spero seph United States Magistrate Judge Judge Jo
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