Jaegel et al v. County of Alameda et al

Filing 48

ORDER re (21 in 4:09-cv-03181-CW), (47 in 4:09-cv-00242-CW) Granting Stipulation to Continue CMC Case Management Statement due by 10/5/2010. Case Management Conference set for 10/12/2010 02:00 PM. Signed by Judge Claudia Wilken on 9/13/2010. (ndr, COURT STAFF) (Filed on 9/13/2010)

Jaegel et al v. County of Alameda et al

Doc. 48

1 GREGORY J. ROCKWELL, ESQ. (SBN 67305) [e-mail] 2 JILL P. SAZAMA, ESQ. (SBN 214215) [e-mail] 3 BOORNAZIAN, JENSEN & GARTHE A Professional Corporation 4 555 12th Street, Suite 1800 P. O. Box 12925 5 Oakland, CA 94604-2925 Telephone: [phone] Facsimile: [phone] 7 Attorneys for Defendants 8 9 10 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 09-0242 CW Related Case No.: 09-03181 CW STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER Complaint Filed: January 20, 2009 CMC Hearing Date: September 14, 2010 Time: 2:00 p.m.

MARK ANTHONY JAEGEL SR, MARK 11 ANTHONY JAEGEL JR., Individually and on Behalf of All Others Similarly Situated, 12 Plaintiffs, 13 vs. 14 THE COUNTY OF ALAMEDA, et al., 15 Defendants. 16 17

The undersigned hereby stipulate and jointly respectfully request the Court to order

18 as follows: 19 That due to matters related to other actions, the parties have not been able to

20 timely complete a joint case management conference statement for the joint case 21 management conference set for September 14, 2010 at 2:00 p.m. 22 Further, initial discovery on both cases have been conducted which have resulted

23 in numerous documents being produced. Discovery conducted on each action thus far 24 are as follows: 25 Case number 09-0242 CW: Interrogatories, Requests for Admissions and

26 Requests for Production of Documents have been propounded by Plaintiffs to all 27 28
-1STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER Jaegel, et al. vs. The County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-0242 CW Jaegel v. County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-03181 CW
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1 Defendants. Numerous documents have been have been provided by Defendants in 2 response to discovery and plaintiffs are awaiting supplemental responses and 3 4 5 6 7 documents. Plaintiffs believe the forgoing written discovery primarily in the area of document productions, is a necessary prerequisite to the taking of meaningful depositions. To date, depositions have been taken of Plaintiffs and four (4) Defendant employees and it is expected that additional testimony may be needed once Defendants

8 have complied with Plaintiffs' documents requests. Plaintiffs then can accurately report 9 which additional witness depositions they intend to take. Additional written documents 10 requests are to be propounded by Plaintiffs within the next week. 11 12 13 14 Case No.: 09-03181 CW: Interrogatories and Requests for Admissions have been propounded by Plaintiffs to all Defendants. Plaintiffs are awaiting Defendants responses. All parties concede the Case Management Conference be continued so that

15 parties can conduct the above discovery and have a better sense of what other discovery 16 may be required, if any, in addition to having a better perspective on time and offering the 17 Court future hearing dates and deadlines that are determined during the Case 18 Management Conference. 19 20 21 22 23 24 25 26 27 28
-2STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER Jaegel, et al. vs. The County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-0242 CW Jaegel v. County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-03181 CW

Wherefore the parties jointly request that the Court order as follows: That the case management conference in both of the above actions set for September 14, 2010 at 2:00 p.m. may be continued to October 12, 2010 at 2:00 p.m., or such other date and time as the court may order.

1

That the parties file a joint case management conference statement no later than

2 October 5, 2010. 3 4 5 6 7 8 DATED: September 10, 2010 9 10 11 12 13 DATED: September 10, 2010 14 15 16 17 18 MICHEL F. MILLS, Attorney At Law By: /s/ Michel F. Mills_____________ MICHEL F. MILLS, ESQ. Attorneys for Plaintiffs ORDER Good Cause appearing therefore, the Case Management Conference set for JOHN R. COGORNO, Attorney At Law By: /s/ John R. Cogorno_____________ JOHN R. COGORNO, ESQ. Attorneys for Plaintiffs DATED: September 10, 2010 BOORNAZIAN, JENSEN & GARTHE A Professional Corporation By: /s/Gregory J. Rockwell____________ GREGORY J. ROCKWELL, ESQ. Attorneys for Defendants

19 September 14, 2010 at 2:00 p.m. in actions 09-0242CW and 09-03181CW is hereby 20 continued to October 12, 2010 at 2:00 p.m. The parties shall file a joint case

21 management conference statement no later than October 5, 2010. 22 23 24 25 26 27 28
-3STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND PROPOSED ORDER Jaegel, et al. vs. The County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-0242 CW Jaegel v. County of Alameda, et al.; USDC ­ Nor. Dist. Case No. 09-03181 CW

Dated: 9/13/2010 ____________________________________ CLAUDIA WILKEN United States District Judge