Cozzi et al v. County of Marin et al

Filing 126

ORDER EXTENDING DEADLINE TO FILE PRETRIAL SUBMISSIONS TO APRIL 23, 2010 re 125 Letter filed by Margaret A. Turner, Joan G. Monteverdi, Mario Zamudio, Maria Cozzi, Yun Bin Hsu, Beverly Hodges, Thomas R. Watson, Gretchen Melendy, Martha Grigsby, Marybeth Pascale, County of Marin, Monica H. Patenaude. Signed by Judge Phyllis J. Hamilton on 4/5/10. (nah, COURT STAFF) (Filed on 4/5/2010)

PATRICK K. FAULKNER
COUNTY COUNSEL

COUNTY COUNSEL OF MARIN COUNTY
3501 Civic Center Drive, Suite 275 San Rafael, California 94903-5222 [phone]

JACK F. GOVI ASSIST ANT COUNT Y COUNSEL DOROTHY R. JONES
CHIEF DEPUTY

FAX (415) T DD (415)

499-3796 473-2226

MARI-ANN G. RIVERS RENEE GIACOMINI BREW ER DAVID L. ZALT SMAN MICHELE KENO NANCY ST UART GRISHAM JENNIF ER M. W. VUILLERMET PATRICK M. K. RICHARDSON THOMAS F. LYONS ST EPHEN R. RAAB ST EVEN M. PERL SHEILA SHAH LICHT BLAU EDW ARD J. KIERN AN JESSICA F. MILLS DEPUT IES JEANINE MICHAELS ADMINISTRATIVE ASSISTANT

April 2, 2010 Via Electronic Filing and Copy to Judge James's Chambers The Honorable Phyllis J. Hamilton 1301 Clay Street, 400S Third Floor, Courtroom 3 Oakland, CA 94612 Re: Cozzi v. County of Marin, C 08 3633 PJH Letter seeking guidance regarding pretrial submissions

Dear Honorable Judge Phyllis J. Hamilton: This letter is a joint submission from counsel for all parties in the action. The trial regarding plaintiff Martha Grigsby is scheduled to begin on June 7, 2010. On April 13, the joint pretrial statement, trial briefs, motions in limine, deposition excerpts, witness lists and exhibits to be offered as evidence of the parties are due. On February 10, 2010, a hearing took place regarding the summary judgment motion of all defendants against Martha Grigsby. The parties have conducted the ordered meet and confer prior to the pretrial conference, and agree that the Court's ruling on the summary judgment may have a significant impact upon all pretrial submissions. Therefore, the parties request that the Court reschedule the date the pretrial submissions are due from April 13 to April 23. The parties stipulate that the time to oppose and motions in limine would not change from the pretrial order, in which oppositions to any motions in limine were due April 28, 2010. Therefore, the parties would not change the date that the last submission of the parties was due before the pretrial conference. If the April 23 date for the parties' pretrial submissions is not acceptable to the Court, the parties request guidance from the Court regarding an appropriate date for the pretrial submissions to allow the parties more time to prepare, and also for the potential to receive an order regarding the summary judgment motion involving Martha Grigsby.

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Sincerely, /s/ Stephen R. Raab Attorneys for Defendants Sincerely, /s/ David M. Poore Attorney for Plaintiffs

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