Collins et al v. County of San Mateo et al

Filing 60

STIPULATION AND ORDER re 59 STIPULATION WITH PROPOSED ORDER to Amend Case Management and Pre-Trial Order for Jury Trial filed by S.C. (minor), Kornelia Collins, George Collins. Signed by Judge Edward M. Chen on October 25, 2017. (wsn, COURT STAFF) (Filed on 10/25/2017)

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ROBERT R. POWELL, SBN 159747
SARAH E. MARINHO, SBN 293690
POWELL & ASSOCIATES
925 West Hedding Street
San Jose, California 95126
T: [phone] F: [phone]
E: [e-mail]
Attorneys for Plaintiffs

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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GEORGE COLLINS, et al.,
Plaintiffs,

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vs.

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Case No. 16-cv-05629-EMC
STIPULATION AND [PROPOSED]
ORDER TO AMEND CASE
MANAGEMENT AND PRE-TRIAL
ORDER FOR JURY TRIAL

COUNTY OF SAN MATEO, et al.,
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Defendants.

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RECITALS
The parties, through counsel, appeared on 10/3/17 for a Scheduling Conference with the
Court. As a result, the Court filed a Case Management And Pre-Trial Order For Jury Trial

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(Dkt. 58 – “Pre-Trial Order”) specifying typical pre-trial orders regarding discovery cut-off
dates, expert report exchange dates, trial, etc.
Counsel consulted thereafter, and based on a significant travel plan of Defendants’
Counsel Mr. Levy in the month of May 2018, and a rather difficult alignment in the original

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Pre-Trial Order of the opening Expert Reports being due the same date as the Fact Discovery
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Cut-off (4/19/18), Counsel are jointly stipulating, and asking this Court to agree to amend the
Pre-Trial Order as set forth in the attached submission (Exhibit A) of a completed and ready-

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______________________________________________________________________________________
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Stipulation of the Parties and [Proposed] Order re: Amend Pre-Trial Order
Collins, et al. v. County of San Mateo, et al.
U.S. District Court – Northern District
Case No. 16-cv-05629-TEH

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for-filing version of an Amended Case Management And Pre-Trial Order For Jury Trial.
In the attached version, the following changes were made;

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1 – The Non-Expert Discovery Cut-off moved from 4/19/18 to 3/9/18
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2 – Exchange of Expert opening reports moved from 4/19/18 to 3/23/18

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3 – Exchange of Expert rebuttal reports moved from 5/10/18 to 4/13/18

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4 – Expert Discovery Cut-Off moved from 5/31/18 to 5/3/18

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IT IS SO STIPULATED

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Dated: October 24, 2017

__/s/ Robert R. Powell____________
Robert R. Powell
Attorney for Plaintiffs

Dated: October 24, 2017

_/s/ David A. Levy_______________
David A. Levy, Deputy County Counsel
Attorney for Defendants

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Pursuant to L.R. 5-1(i)(3), the filer of this document
attests that he has received the concurrence of this
signatory to file this document.

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[PROPOSED] ORDER

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The Court hereby adopts the Stipulation of the parties hereinabove, and orders the
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Amended Case Management And Pre-Trial Order For Jury Trial as attached to this Stipulation

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be signed and filed, replacing the Pre-Trial Order at Docket #58, as the operative Case

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Management And Pre-Trial Order For Jury Trial.

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IT IS SO ORDERED

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Dated: ________ 2017
October 25,

_____________________________
HON. EDWARD M. CHEN
U.S. DISTRICT COURT JUDGE

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______________________________________________________________________________________
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Stipulation of the Parties and [Proposed] Order re: Amend Pre-Trial Order
Collins, et al. v. County of San Mateo, et al.
U.S. District Court – Northern District
Case No. 16-cv-05629-TEH