Beltran et al v. County of Santa Clara et al

Filing 185

STIPULATION AND ORDER 184 to Continue Trial and All Pretrial Deadlines: Jury Trial set for 10/26/2009 01:30 PM in Courtroom 6, 4th Floor, San Jose. Pretrial Conference set for 10/15/2009 02:00 PM in Courtroom 6, 4th Floor, San Jose. Signed by Judge Ronald M. Whyte on 3/26/09. (jg, COURT STAFF) (Filed on 3/26/2009)

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A N N M IL L E R R A V E L C o u n ty C o u n s e l C o u n ty o f S a n ta C la r a S a n Jo s e , C a l i fo r n i a

ANN MILLER RAVEL, County Counsel (S.B. #62139) MELISSA R. KINIYALOCTS, Deputy County Counsel (S.B. #215814) OFFICE OF THE COUNTY COUNSEL 70 West Hedding, East Wing, 9th Floor San Jose, California 95110-1770 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants EMILY TJHIN AND MELISSA SUAREZ ROBERT R. POWELL, Esq. (S.B. #159747) DENNIS INGOLS, Esq. (S.B. #236548) LAW OFFICES OR ROBERT R. POWELL 925 West Hedding Street San Jose, California 95126 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs LORI BELTRAN, ROBERT BELTRAN, and COBY BELTRAN, by and through his Guardian Ad Litem LORI BELTRAN

*E-FILED - 3/26/09*

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (San Jose)

) ) Plaintiffs, ) ) v. ) ) COUNTY OF SANTA CLARA et al., ) ) Defendants. ) __________________________________)

LORI BELTRAN et al.,

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STIPULATION AND ORDER TO CONTINUE TRIAL AND ALL PRETRIAL DEADLINES

The parties in the above-captioned matter submit the following Stipulation and Proposed Order for the purpose of requesting that the Court continue the trial, presently set for April 20, 2009, and the pretrial conference, presently set for April 9, 2009. This request is based on the ground that Defendant Melissa Suarez is experiencing complications with her pregnancy and has been placed on bed rest by her doctor until her estimated date of delivery of June 16, 2009,
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and through postpartum recovery until July 28, 2009. Attached as Exhibit A is a true and correct copy of a note from Ms. Suarez's doctor that states these restrictions. Discovery in this matter, including expert discovery, is closed. By this stipulation the parties do not intend to re-open discovery. Further, Defendants' motion for summary judgment, which was heard on February 27, 2009, is pending. Accordingly, the parties stipulate to continue the trial date to October 26, 2009, and the pretrial conference to October 15, 2009. The pretrial deadlines to serve, file, and/or lodge documents in accordance with the Court's Standing Order Re: Pretrial Preparation shall be calculated according to the October 15, 2009 pretrial conference. I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document. ANN MILLER RAVEL County Counsel Dated: March 18, 2009 By: /S/ MELISSA R. KINIYALOCTS Deputy County Counsel Attorneys for Defendants EMILY TJHIN and MELISSA SUAREZ

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Dated: March 18, 2009

By: ROBERT R. POWELL Attorney for Plaintiffs LORI BELTRAN, ROBERT BELTRAN, and COBY BELTRAN

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A N N M IL L E R R A V E L C o u n ty C o u n s e l C o u n ty o f S a n ta C la r a S a n Jo s e , C a l i fo r n i a

ORDER CONTINUING THE TRIAL DATE The Court, having considered the stipulation of the parties and finding good cause, hereby orders that the trial date in this matter is continued to October 26, 2009 and the pretrial conference to October 15, 2009. The pretrial deadlines to serve, file, and/or lodge documents in accordance with the Court's Standing Order Re: Pretrial Preparation shall be calculated according to the October 15, 2009 pretrial conference. Joint Pretrial Statement due IT IS SO ORDERED.

October 9, 2009.

3/ _6/ _9 Dated:____2__0_________

_________________________________ HONORABLE RONALD M. WHYTE United States District Court Judge

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