Neuroth et al v. Mendocino County et al

Filing 341

STIPULATION AND ORDER RE 340 TO MODIFY CASE MANAGEMENT SCHEDULING ORDER AND OTHER DATES. Pretrial Conference set for 12/6/2018 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Judge Richard Seeborg on 8/29/18. (cl, COURT STAFF) (Filed on 8/29/2018)

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1 2 3 4 5 6 7 8 9 John W. Patton, Jr., Pro Hac Vice Michael G. Vranicar, SBN 131842 PATTON & RYAN LLC 330 North Wabash Ave., Suite 3800 Chicago, Illinois 60611 Telephone: (312) 261-5160 Facsimile: (312) 261-5161 Email: jpatton@pattonryan.com mvranicar@pattonryan.com Attorneys for Defendants the County of Mendocino and Mendocino County SheriffCoroner Thomas Allman, Capt. Timothy Pearce, Lorrie Knapp, Frank Masterson, Craig Bernardi, Michael Grant, Jeanette Holum, Robert Page, & Christine De Los Santos 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 JAMES NEUROTH, et al., Case No. 3:15-CV-03226-RS 13 Plaintiffs, 14 v. 15 MENDOCINO COUNTY, et al., JOINT STIPULATION TO MODIFY CASE MANAGEMENT SCHEDULING ORDER AND OTHER DATES; [PROPOSED] ORDER 16 Defendants. 17 18 19 20 21 22 23 24 25 26 27 This Joint Stipulation to Modify Case Management Scheduling Order is submitted by all parties in this action, through their respective counsel, including: Plaintiff James Neuroth (“Plaintiff”); Defendants the County of Mendocino, Mendocino County Sheriff Thomas Allman, Sheriff’s Captain Timothy Pearce, and current/former Sheriff’s Deputies Lorrie Knapp, Frank Masterson, Craig Bernardi, Michael Grant, Jeanette Holum, Robert Page, and Christine De Los Santos (collectively, “County Defendants”); California Forensic Medical Group, Inc., Dr. Taylor Fithian, and LVN Jennifer Caudillo (collectively, “CFMG Defendants”); Correctional Medical Group Companies, Inc., RN Elaine Hustedt, and RN Claire Teske (collectively, “CMGC Defendants”); and the City of Willits, former Willits Police Chief Gerardo Gonzalez, and current/former Willits Police Officers Kevin Leef and Jeff Andrade (collectively, the “Willits 28 Joint Stipulation to Modify Case Management Scheduling Order and Other Dates; [Proposed] Order Neuroth, et al. v. Mendocino County, et al., U.S.D.C. No. 3:15-cv-03226-RS 1 1 Defendants”). Pursuant to this Stipulation, the parties jointly request the Court to modify the pretrial 2 dates set out in its previous Case Management Scheduling Order entered on December 13, 2017 3 (Dkt. No. 232, the “Scheduling Order”), as well as other dates, as set forth below. 4 5 RECITALS A. The course and schedule of events in this case have caused the parties to reevaluate 6 the remaining dates set in the Court’s previous Scheduling Order (Dkt. No. 232), which are presently 7 as follows: • 8 9 August 30, 2018: Last day to conduct meet and confer session (per the Court’s Jury Trial Standing Order, Section A). September 13, 2018: Last day to file Motions in Limine, and last day to file Joint Pretrial Statement and Proposed Order (per the Court’s Jury Trial Standing Order, Section B). 10 11 October 4, 2018: Oppositions to Motions in Limine due 12 October 18, 2018, at 10:00 a.m.: Final Pretrial Conference 13 14 B. The parties request the Court to revise the pretrial dates set out in the previous 15 Scheduling Order for the following reasons: 16 1. The Court’s request to revise the scheduling order due to the delay in the 17 hearing on the Motions for Summary Judgment. 18 2. The parties are mindful of the Court’s busy docket, and that it may take 19 considerable time for the Court to issue a summary judgment order after the hearing on those 20 motions. 21 WHEREFORE, the parties hereby agree and request entry of an order as follows: 22 AGREEMENT 23 1. The parties request the Court to consider modifying the scheduling guidelines set out 24 in its Jury Trial Standing Order in this case as follows: 25 26 27 28 a. September 12, 2018: Last day to conduct meet and confer session (per the Court’s Jury Trial Standing Order, Section A). b. October 18, 2018: Last day to file Motions in Limine, and last day to file Joint Pretrial Statement and Proposed Order (per the Court’s Jury Trial Joint Stipulation to Modify Case Management Scheduling Order and Other Dates; [Proposed] Order Neuroth, et al. v. Mendocino County, et al., U.S.D.C. No. 3:15-cv-03226-RS 2 Standing Order, Section B). 1 c. November 15, 2018: Oppositions to Motions in Limine due 2 d. December 6, 2018, at 10:00 a.m.: Final Pretrial Conference 3 4 3. Nothing in this Stipulation and request for order is intended to modify the other 5 matters addressed in any Court order unless expressly identified herein, nor does it preclude the 6 parties from seeking additional relief from this Court, to amend this stipulation and order or 7 otherwise. 8 IT IS SO STIPULATED. 9 10 Patton & Ryan LLC 11 /s/ Michael G. Vranicar Michael G. Vranicar Attorneys for County Defendants 12 Law Offices of Jerome M. Varanini 13 Dated: August 28, 2018 14 /s/ Jerome M. Varanini Jerome M. Varanini Attorneys for CFMG Defendants 15 Bertling Law Group, Inc. 16 Dated: August 28, 2018 By: Dated: August 28, 2018 By: By: 17 18 Perry, Johnson, Anders, Miller & Moskowitz LLP 19 20 Dated: August 28, 2018 By: 21 24 25 /s/ Scott A. Lewis Scott A. Lewis Attorneys for Willits Defendants Haddad & Sherwin LLP 22 23 /s/ Peter G. Bertling Peter G. Bertling Attorneys for CMGC Defendants Dated: August 28, 2018 By: /s/ Michael J. Haddad Michael J. Haddad Attorneys for Plaintiff * Approval in the filing of this document has been obtained from all signatories. 26 27 28 Joint Stipulation to Modify Case Management Scheduling Order and Other Dates; [Proposed] Order Neuroth, et al. v. Mendocino County, et al., U.S.D.C. No. 3:15-cv-03226-RS 3 1 ORDER 2 Based on the parties’ stipulation, and with good cause appearing therefore, 3 IT IS HEREBY ORDERED that the previous Case Management Scheduling Order entered 4 on December 13, 2017 (Dkt. No. 232) is hereby modified, and that the following dates are set in the 5 instant case: 6 7 a September 12, 2018: Last day to conduct meet and confer session (per the Court’s Jury Trial Standing Order, Section A). 8 b. October 18, 2018: Last day to file Motions in Limine, and last day to file Joint Pretrial Statement and Proposed Order (per the Court’s Jury Trial Standing Order, Section B). 9 c. November 15, 2018: Oppositions to Motions in Limine due 10 d. December 6, 2018, at 10:00 a.m.: Final Pretrial Conference 11 12 IT IS SO ORDERED. 13 14 15 16 Date: _____________ 8/29/18 ____________________________________ HONORABLE RICHARD SEEBORG United States District Court Judge 17 18 19 20 21 22 23 24 25 26 27 28 Joint Stipulation to Modify Case Management Scheduling Order and Other Dates; [Proposed] Order Neuroth, et al. v. Mendocino County, et al., U.S.D.C. No. 3:15-cv-03226-RS 4

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