Davis et al v. California Department of Corrections and Rehabilitation et al

Filing 209

ORDER by Judge Saundra Brown Armstrong Granting 200 Stipulation CONTINUING DEADLINE FOR DISPUTED JURY INSTRUCTIONS AND SUPPORTING MEMORANDA. (ndr, COURT STAFF) (Filed on 9/17/2013)

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EDMUND G. BROWN JR.
Attorney General of California
MIGUEL A. NERI
FIEL D. TIGNO
Supervising Deputy Attorneys General
KAREN KIYO LOWHURST
BONNIE J. CHEN
Deputy Attorney General
State Bar No. 219394
1515 Clay Street, 20th Floor
P.O. Box 70550
Oakland, CA 94612-0550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants CDCR, David Mandel,
Timothy McCarthy

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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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BRENDA DAVIS and DAVID ROY,

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v.

C 08-4481 SBA

Plaintiffs, STIPULATED ORDER CONTINUING
DEADLINE FOR DISPUTED JURY
INSTRUCTIONS AND SUPPORTING
MEMORANDA

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STATE OF CALIFORNIA,
DEPARTMENT OF CORRECTIONS AND
REHABILITATION; DAVID MANDEL,
Ph.D.; TIMOTHY McCARTHY, Ph.D.;
JOANN VAN VALKENBURGH;
MAUREEN McLEAN and DOES 1-100,

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Defendants.

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Date:
Time:
Courtroom:
Judge

October 22, 2013 (Pretrial)
1:00 p.m.
1, 4th Floor
The Honorable Saundra B.
Armstrong
Trial Date
October 28, 2013
Action Filed: September 24, 2008

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Stipulated [Proposed] Order Continuing Deadline For Disputed Jury Instructions and Supporting Memoranda (C 084481 SBA)

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TO THE HONORABLE COURT AND THE CLERK OF THE COURT:

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TAKE NOTICE THAT THE undersigned counsel of record for plaintiffs and defendants

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hereby stipulate and request that the Court enter the following order forthwith:
The parties jointly and respectfully request one extra week to file their separate sets of

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disputed proposed jury instructions with supporting memoranda. The parties are currently

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meeting and conferring in good faith, and plan to timely file a joint set of agreed-upon proposed

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jury instructions on September 17, 2014. The parties agree on a majority of the proposed jury

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instructions, as they are largely based on the Ninth Circuit Manual of Model Jury Instructions,

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where applicable. The parties will need additional time to prepare the memoranda requested for

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the disputed jury instructions mentioned on page 4, paragraph (f) of the Court’s standing order for

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pretrial preparation. The parties are hoping to effectively utilize the Court’s time and resources

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by thoroughly meeting and conferring on these issues prior to the pre-trial conference.

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Stipulated [Proposed] Order Continuing Deadline For Disputed Jury Instructions and Supporting Memoranda (C 084481 SBA)

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The parties respectfully request that the deadline for filing separate sets of disputed
proposed jury instructions with supporting memoranda be extended to September 24, 2013.

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Dated: September 16, 2013

Respectfully submitted,
KAMALA D. HARRIS
Attorney General of California
KAREN KIYO LOWHURST
Deputy Attorney General

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/s/ Bonnie J. Chen
BONNIE J. CHEN
Deputy Attorney General
Attorneys for Defendants CDCR, Mandel
& McCarthy

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Respectfully submitted,

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HAGLUND KELLEY JONES & WILDER, LLP

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/s/ Christopher Lundberg
CHRISTOPHER LUNDBERG
Attorneys for Plaintiff Brenda Davis and
David Roy

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ORDER
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Based on the agreement of the parties, and good cause appearing, it is SO ORDERED.

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The parties’ separate sets of disputed proposed jury instructions and supporting memoranda shall

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be filed no later than September 24, 2013.

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9/17/2013
Dated: __________________

________________________________
SAUNDRA B. ARMSTRONG
United States District Judge

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OK2008900526
90130112.doc

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Stipulated [Proposed] Order Continuing Deadline For Disputed Jury Instructions and Supporting Memoranda (C 084481 SBA)