Jaegel v. County of Alameda et al

Filing 32

ORDER Granting 30 Stipulation. Case Management Statement due by 3/29/2012. Further Case Management Conference set for 4/5/2012 02:00 PM. Motions due by 2/17/2012. Replies due by 3/9/2012. Responses due by 3/2/2012. Reply due by 3/16/2012. Motio n Hearing set for 4/5/2012 02:00 PM before Hon. Claudia Wilken. Final Pretrial Conference set for 5/22/2012 02:00 PM. Jury Selection set for 6/4/2012 08:30 AM before Hon. Claudia Wilken. Jury Trial (5 day) set for 6/4/2012 08:30 AM before Hon. Claudia Wilken. Signed by Judge Claudia Wilken on 9/9/2011. (ndr, COURT STAFF) (Filed on 9/9/2011)

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]
6 Facsimile: [phone]
7 Attorneys for Defendants
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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MARK ANTHONY JAEGEL SR.
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Plaintiff,
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vs.
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THE COUNTY OF ALAMEDA, et al.,
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Defendants.
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Case No.: 09-03181 CW
STIPULATION TO CONTINUE TRIAL
AND PRE-TRIAL DEADLINES
Complaint Filed: July 14, 2009

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By Order dated October 12, 2010, this Court set the above referenced action for trial on

20 November 28, 2011, at 8:30 a.m., in addition to many related pre-trial deadlines.
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The parties have been working diligently to complete discovery.

All parties have

22 exchanged written discovery. The deposition of the plaintiff has been commenced but not
23 completed. Numerous percipient witnesses have been identified and several will need to be
24 subpoenaed for deposition. Plaintiff has taken the depositions of certain defendants and others are
25 to be scheduled. Various issues requiring expert testimony have been identified, but the parties
26 need additional time to complete non-expert discovery before their experts can be fully ready to
27 offer their opinions. Due to scheduled trials with expert depositions in other cases pending for
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-1STIPULATION AND ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES
Jaegel. vs. The County of Alameda, et al.; USDC – Nor. Dist. Case No. 09-03181 CW

1 both sides, the parties believe that it is in the interests of justice and judicial economy for the Court
2 to continue the present trial date and all pending pre-trial dates and they do hereby stipulate and
3 respectfully request that the Court continue said pending deadlines as follows:
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Date of next case management conference: 4/3/2012

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Completion of Fact Discovery: 12/9/2011

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Disclosure of identities and reports of expert witnesses: 1/6/2012

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Completion of Expert Discovery: 3/2/2012

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All case-dispositive motions to be heard at 2:00 p.m. on or before: 4/3/2012

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Plaintiffs’ counsel intends to file a Motion for Summary Judgment. Plaintiffs’ opening

10 brief due: 2/17/12
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Defendants’ opposition/cross motion (contained within a single brief) due: 3/2/2012

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Plaintiffs’ reply/opposition to cross motion (contained within a single brief) due: 3/9/2012

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Defendants’ reply due: 3/16/2012

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Final Pre-Trial Conference at 2:00 p.m. on: 5/22/2012

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A 5 day Jury Trial will begin at 8:30 a.m. on: 6/4/2012

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Accordingly, the parties respectfully request and jointly stipulate to the above listed

17 continuances.
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It is so stipulated.

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20 DATED: July 7, 2011
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BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation

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By: /s/Gregory J. Rockwell____________
GREGORY J. ROCKWELL, ESQ.
Attorneys for Defendants

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-2STIPULATION AND ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES
Jaegel. vs. The County of Alameda, et al.; USDC – Nor. Dist. Case No. 09-03181 CW

1 DATED: July 7, 2011
JOHN R. COGORNO, Attorney At Law

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By: /s/ John R. Cogorno_____________
JOHN R. COGORNO, ESQ.
Attorneys for Plaintiff

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ORDER
GOOD CAUSE appearing therefor, and the parties having so stipulated, it is hereby

9 ordered that the above listed continuances are GRANTED. except that the case management
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10 conference and motion hearing will be held on April 5, 2012, not April 3.
11 Dated: 9/9/2011
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CLAUDIA WILKEN
United States District Judge

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24269\547585

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-3STIPULATION AND ORDER TO CONTINUE TRIAL AND PRE-TRIAL DEADLINES
Jaegel. vs. The County of Alameda, et al.; USDC – Nor. Dist. Case No. 09-03181 CW