Frausto v. California Highway Patrol et al

Filing 81

STIPULATION AND ORDER 80 Extending Expert Discovery Cut-Off Deadline. Signed by Judge Richard Seeborg on 2/8/17. (cl, COURT STAFF) (Filed on 2/8/2017)

1 GREGORY B. THOMAS, ESQ. (SBN 239870)
ADAM A. VUKOVIC, ESQ. (SBN 301392)
2 SOPHIA V. COHN, ESQ. (SBN 306661)
BOORNAZIAN, JENSEN & GARTHE
3 A Professional Corporation
555 12th Street, Suite 1800
4 Oakland, CA 94607
Telephone: [phone]
5 Facsimile: [phone]
[e-mail]
6 [e-mail]
[e-mail]
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Attorneys for Defendant
8 COUNTY OF ALAMEDA, sued herein as “ALAMEDA COUNTY SHERIFF’S OFFICE,”
KEVIN BEYRODT, AARON INNS, ANTHONEY FIELDS, IVAN STEWART, KAREN
9 EASLING, sued herein as “K. EASLING,” and CAMERON TRACY
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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14 YOLANDA FRAUSTO individually and as )
successor in interest to the Estate of Decedent )
15 John Anthony Cornejo,
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Plaintiffs,
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vs.
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CALIFORNIA HIGHWAY PATROL,
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19 ALAMEDA COUNTY SHERIFF’S OFFICE, )
KEVIN BEYRODT, NORMAND D.
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20 CORNEJO, II, and DOES 1 to 30, inclusive, )
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Defendants.
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22 And Related Actions
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Case No.: 3:16-cv-00311-RS
And Related Actions
STIPULATION AND [PROPOSED]
ORDER EXTENDING EXPERT
DISCOVERY CUT-OFF DEADLINE

The parties submit the following Joint Stipulation and request that the Court grant a one

25 month extension of the expert discovery cut-off deadline, presently set for February 15, 2017. Due
26 to expert availability and other scheduling conflicts, the parties do not have enough time to take
27 the necessary expert depositions by that date. This request will not affect any other deadlines.
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-1STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY CUT-OFF DEADLINE
Yolanda Frausto v. County of Alameda, et al. - Case No.: 3:16-cv-0311-RS; and related actions

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Therefore, the parties hereby stipulate and request that the Court grant an extension on the

2 expert discovery cut-off deadline until March 17, 2017.
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Respectfully submitted,

4 DATED: February 7, 2017
BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation

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By: ___/s/ Gregory B. Thomas
GREGORY B. THOMAS, ESQ.
ADAM A. VUKOVIC, ESQ.
SOPHIA V. COHN, ESQ.
Attorneys for Defendant
COUNTY OF ALAMEDA, sued
herein as “ALAMEDA COUNTY
SHERIFF’S OFFICE,” KEVIN
BEYRODT, AARON INNS,
ANTHONEY FIELDS, IAN
STEWART, KAREN EASLING,
sued herein as “K. EASLING,” and
CAMERON TRACY

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15 DATED: February 7, 2017

BRACAMONTES & VLASAK, P.C.

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By: __/s/ Michael Bracamontes____
MICHAEL BRACAMONTES, ESQ.
MICHAEL A. SCHREIBER, ESQ.
Attorneys for Plaintiffs
YOLANDA FRAUSTO
NORMAN CORNEJO

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DATED: February 7, 2017

CALIFORNIA ATTORNEY GENERAL

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By: __/s/ Craig Modlin, Esq.____
CRAIG MODLIN, ESQ.
Attorney for Defendants
CALIFORNIA HIGHWANT PATROL, M.
DIEHL, Z. TRZESNIEWSKI, H. SCHULTZ,
C. BRUNO, D. HAZELWOOD, and J.
KOVEN

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-2STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY CUT-OFF DEADLINE
Yolanda Frausto v. County of Alameda, et al. - Case No.: 3:16-cv-0311-RS; and related actions

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ATTESTATION
I, Gregory B. Thomas, am counsel for Record for Defendants County of Alameda, et al. I am

3 the registered ECF user whose username and password are being used to file this stipulation. In
4 compliance with Local Rule 5-1(i)(3), I hereby attest that the above-identified counsel concurred in
5 this filing.
6 Dated: February 7, 2017

BOORNAZIAN, JENSEN & GARTHE

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By: _/s/ Gregory B. Thomas_______________
GREGORY B. THOMAS
Attorney for Defendants
COUNTY OF ALAMEDA, sued herein
as “ALAMEDA COUNTY SHERIFF’S
OFFICE,” KEVIN BEYRODT,
AARON INNS, ANTHONEY FIELDS,
IVAN STEWART, KAREN
EASLING, sued herein as “K.
EASLING,” and CAMERON TRACY

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-3STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY CUT-OFF DEADLINE
Yolanda Frausto v. County of Alameda, et al. - Case No.: 3:16-cv-0311-RS; and related actions

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[PROPOSED] ORDER
GOOD CAUSE appearing, it is ORDERED that Parties’ Joint Stipulation and request that

4 the Court grant an extension of the expert discovery cut-off deadline until March 17, 2017 is
5 GRANTED.
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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8 DATED: _______________________
2/8/17
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HON. RICHARD SEEBORG
Judge of the United States District Court

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-4STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY CUT-OFF DEADLINE
Yolanda Frausto v. County of Alameda, et al. - Case No.: 3:16-cv-0311-RS; and related actions