Marlene Henderson et al v. County of Santa Cruz et al

Filing 116

ORDER granting 115 STIPULATION TO AMEND SCHEDULING ORDER. Reply to 101 MOTION for Summary Judgment due by 7/24/2020. Signed by Judge William H. Orrick on 07/14/2020. (jmdS, COURT STAFF) (Filed on 7/14/2020)

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Jody Struck (SBN 121097)
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant
COUNTY OF SANTA CRUZ, also erroneously sued herein as
THE SANTA CRUZ COUNTY SHERIFF’S DEPARTMENT and
THE SANTA CRUZ COUNTY HEALTH SERVICES AGENCY)

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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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Michael J. Curls (SBN 159651)
Nichelle D. Jones (SBN 186308)
LAW OFFICE OF MICHAEL J. CURLS
4340 Leimert Boulevard, Suite 200
Los Angeles, California 90008
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiffs MARLENE HENDERSON,
THE ESTATE OF EDYTH HENDERSON, and
THE ESTATE OF JOSEPH HENDERSON

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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MARLENE HENDERSON, THE ESTATE OF
EDYTH HENDERSON, and THE ESTATE OF
JOSEPH HENDERSON,

Case No.: 5:14-cv-03544 WHO (HRL)
STIPULATION AND [PROPOSED]
ORDER TO AMEND SCHEDULING
ORDER

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Plaintiffs,
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vs.
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COUNTY OF SANTA CRUZ, THE SANTA
CRUZ COUNTY SHERIFF’S DEPARTMENT,
THE SANTA CRUZ COUNTY HEALTH
SERVICES AGENCY, and DOES 1
THROUGH 25, INCLUSIVE,

Defendants.

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Henderson, et al. v. County of Santa Cruz, et al.,/Case No. 5:14-cv-03544 WHO (LJB)
STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

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TO THE HONORABLE COURT:

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This stipulation is entered into by and between Plaintiffs and Defendant, by and through

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their respective counsel.

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1.

The current trial date in this case is January 4, 2021.

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2.

Defendant moved for summary judgment which is now set for hearing on August

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19, 2020. Defendant recently agreed to provide Plaintiffs’ counsel with a two-week extension

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of time to file and serve the opposition to Defendant’s motion for summary judgment in this

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case. The opposition was filed July 10, 2020 and the reply is currently due July 17, 2020.

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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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3.

Since submitting the last stipulation regarding the continuance for Plaintiff’s

opposition, defense counsel has received several matters which will require significant work in
the next week. The parties have stipulated to a short continuance of one week for Defendant to
file its reply in support of its motion for summary judgment. This continuance will not affect

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the hearing date or any other deadlines.
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4.

The parties further stipulate to continue the designation of and discovery

regarding expert witnesses, to allow the Court an opportunity to consider and rule on the motion
for summary judgment, and to allow for further settlement discussions without the added burden
of expert costs and fees. The continuance of the expert designation, rebuttal witness

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designation, and expert discovery cut-off dates will not affect the trial date, and are in the

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interests of judicial economy.

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5.

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IT IS HEREBY STIPULATED by the Parties, subject to approval by this Court, that the

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Based on the foregoing:

Scheduling Order be amended as follows:

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Reply re: Motion for Summary Judgment:

July 24, 2020

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Hearing on Motion for Summary Judgment:

August 19, 2020

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Expert Witness Designation and Exchange:

September 21, 2020

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Rebuttal Expert Witness Designation and Exchange:

October 5, 2020

Expert Discovery Cutoff:

November 16, 2020

Pre-Trial Conference:

November 30, 2020

Trial Date:

January 4, 2021

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Henderson, et al. v. County of Santa Cruz, et al.,/Case No. 5:14-cv-03544 WHO (LJB)
STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

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Dated: July 13, 2019

LAW OFFICES OF MICHAEL J. CURLS

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By:
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*/s/ Nichelle D. Jones
Nichelle D. Jones
Attorney For Plaintiffs
*Ms. Jones provided her consent to file
this document electronically

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Dated: July 13, 2019

HAAPALA, THOMPSON & ABERN, LLP

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By:

/s/ Jody Struck
Jody Struck
Attorneys for Defendants

Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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Henderson, et al. v. County of Santa Cruz, et al.,/Case No. 5:14-cv-03544 WHO (LJB)
STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER

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ORDER
PER STIPULATION OF COUNSEL, as modified below, IT IS HEREBY ORDERED
that the Scheduling Order be amended as follows, with new dates underlined:

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Reply re: Motion for Summary Judgment:

July 24, 2020

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Hearing on Motion for Summary Judgment:

August 19, 2020

Expert Witness Designation and Exchange:

September 21, 2020

Rebuttal Expert Witness Designation and Exchange:

October 5, 2020

Expert Discovery Cutoff:

October 23, 2020*

Pre-Trial Conference:

November 30, 2020

Trial Date:

January 4, 2021

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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
Facsimile: 510-273-8534

Haapala, Thompson & Abern LLP

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*date changed from stipulation to allow the parties to address any issues regarding
experts in briefing prior to the Pre-Trial Conference

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Dated: July 14, 2020
District Judge William H. Orrick

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Henderson, et al. v. County of Santa Cruz, et al.,/Case No. 5:14-cv-03544 WHO (LJB)
STIPULATION AND [PROPOSED] ORDER TO AMEND SCHEDULING ORDER