Stallworth v. County of Santa Clara et al

Filing 26

ORDER GRANTING AS MODIFIED 25 STIPULATION TO CONTINUE TRIAL AND ALL PRETRIAL DEADLINES:Fact Discovery due by 4/8/2013. Expert Discovery due by 5/13/2013. Dispositive Motions due by 1/15/2013. Jury Selection set for 7/10/2013 08:00 AM in Courtro om 11, 19th Floor, San Francisco before Hon. Jeffrey S. White. Jury Trial set for 7/15/2013 08:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White. Motion Hearing set for 3/15/2013 09:00 AM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White. Pretrial Conference set for 6/24/2013 02:00 PM in Courtroom 11, 19th Floor, San Francisco before Hon. Jeffrey S. White.. Signed by Judge Jeffrey S. White on 9/25/12. (jjoS, COURT STAFF) (Filed on 9/25/2012)

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Case3:11-cv-04841-JSW Document25 Filed09/24/12 Page1 of 3 1 2 3 4 LORI E. PEGG, Acting County Counsel (S.B. #129073) MARY L. MALYSZ, Deputy County Counsel (S.B. #138385) ARYN PAIGE HARRIS, Deputy County Counsel (S.B. #208590) OFFICE OF THE COUNTY COUNSEL 70 West Hedding Street, East Wing, Ninth Floor San Jose, California 95110-1770 Telephone: (408) 299-5900 Facsimile: (408) 292-7240 5 6 7 8 Attorneys for Defendants COUNTY OF SANTA CLARA, ANDREA BROLLINI, MICHELLE DE LA CALLE, and SANTA CLARA COUNTY PERSONNEL BOARD 9 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN FRANCISCO) 10 11 12 KATHLEEN STALLWORTH, 13 14 15 16 No. CV11-04841 JSW Plaintiff, STIPULATION AND PROPOSED ORDER TO CONTINUE TRIAL AND ALL PRETRIAL DEADLINES AS MODIFIED HEREIN v. ANDREA BROLLINI, et al., Defendants. 17 18 19 20 21 22 23 24 25 26 27 28 The parties in the above-captioned matter submit the following Stipulation and Proposed Order for the purpose of requesting that the Court continue the trial, presently set for April 1, 2013, to July 15, 2013. Good cause exists for granting the requested continuance. Plaintiff’s counsel recently noticed the depositions of seven employees of Santa Clara Valley Medical Center, five of whom work in the Emergency Department, and intends to notice additional employee depositions. To avoid a disruption in service in the Emergency Department and to accommodate the schedules of all of these employees, the parties anticipate needing until mid-November to complete these depositions. Additionally, disputes regarding written discovery responses have arisen, and the “meet and confer” process is ongoing. Finally, the dispositive motion cutoff of December 14, 2012 needs Stipulation and Proposed Order to Continue Trial and All Pretrial Deadlines 1 CV11-04841 JSW Case3:11-cv-04841-JSW Document25 Filed09/24/12 Page2 of 3 1 to be continued so that the parties have sufficient time to complete depositions, resolve remaining 2 discovery disputes, and submit the mandamus claim to the Court for review. 3 Accordingly, the parties through their counsel stipulate to continue the trial date to July 15, 4 2013, and the pretrial conference to June 24, 2013. As for the remaining pretrial deadlines, a further 5 Case Management Conference may be warranted, and the parties propose the following: 6 First Day to File Dispositive Motion: January 15, 2013. 7 Discovery Cutoff: Fact Cutoff – April 8, 2013. 8 Last Day for Plaintiff to Disclose Expert Witnesses – April 8, 1013. 9 Last Day for Defendants to Disclose Expert Witnesses – April 22, 2013. 10 Discovery Cutoff: Expert Cutoff – May 13, 2013. 11 Last Day to Hear Dispositive Motions – March 8, 2013. 12 I hereby attest that I have on file the holograph signature indicated by a “conformed” 13 signature (/S/) within this efiled document. 14 Dated: September 24, 2012 Respectfully submitted, LORI E. PEGG Acting County Counsel 15 16 By: 17 /S/ MARY L. MALYSZ Deputy County Counsel 18 19 Attorneys for Defendants COUNTY OF SANTA CLARA, ANDREA BROLLINI, MICHELLE DE LA CALLE, and SANTA CLARA PERSONNEL BOARD 20 21 22 Dated: September 24, 2012 By: /S/ BLAINE L. FIELDS 23 Attorney for Plaintiff KATHLEEN STALLWORTH 24 25 26 27 28 Stipulation and Proposed Order to Continue Trial and All Pretrial Deadlines 2 CV11-04841 JSW Case3:11-cv-04841-JSW Document25 Filed09/24/12 Page3 of 3 1 ORDER CONTINUING THE TRIAL DATE 2 The Court, having considered the stipulation of the parties and finding good cause, hereby 3 orders that the trial date in this matter is continued to July 15, 2013, and the pretrial conference to 4 June 24, 2013. The remaining pretrial deadlines are continued, as follows: 5 First Day to File Dispositive Motion – January 15, 2013. 6 Discovery Cutoff: Fact Cutoff – April 8, 2013. 7 Last Day for Plaintiff to Disclose Expert Witnesses – April 18, 1013. 8 Last Day for Defendants to Disclose Expert Witnesses – April 22, 2013. 9 Discovery Cutoff: Expert Cutoff – May 13, 2013. 10 11 12 Last Day to Hear Dispositive Motions – March 8, 2013.March 15, 2013 Jury selection will be held on July 10, 2013 at 8:00 a.m. Dated: September 25, 2012 JUDGE JEFFREY S. WHITE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stipulation and Proposed Order to Continue Trial and All Pretrial Deadlines 3 CV11-04841 JSW

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