Watson et al v. County of Santa Clara et al
Filing
361
STIPULATION AND ORDER 359 to Modify Scheduling Order. Jury Trial set for 11/1/2010 01:30 PM in Courtroom 6, 4th Floor, San Jose. Pretrial Conference set for 10/14/2010 02:00 PM in Courtroom 6, 4th Floor, San Jose. Signed by Judge Ronald M. Whyte on 5/20/10. (jgS, COURT STAFF) (Filed on 5/20/2010)
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M IG U E L M Á R Q U E Z A c tin g 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
MIGUEL MÁRQUEZ, Acting County Counsel (S.B. #184621) MELISSA R. KINIYALOCTS, Lead Deputy County Counsel (S.B. #215814) DAVID ROLLO, Deputy County Counsel (S.B. #111998) GREGORY J. SEBASTINELLI, Deputy County Counsel (S.B. #104884) OFFICE OF THE COUNTY COUNSEL 70 West Hedding, East Wing, 9th Floor San Jose, California 95110-1770 Telephone: (408) 299-5900 Facsimile: (408) 292-7240 Attorneys for Defendants COUNTY OF SANTA CLARA, NORMA SPARKS, YAZMINA LETONA, SHARON BURGAN, LINDA CASTALDI, JEWELS RAMIREZ, VU TRAN, RIMA SINGH, AARON WEST, JOHN HAMILTON, ANITA NOBLE, JANET KAHLE, MARY RITTER, DAVID KEARNS, and ELISABETH MAILHOT, M.D.
*E-FILED - 5/20/10*
UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA (San Jose Division)
) ) Plaintiffs, ) ) v. ) ) COUNTY OF SANTA CLARA et al., ) ) Defendants. ) __________________________________)
TRACY WATSON et al.,
No.
C06-4029 RMW
STIPULATION AND ORDER TO MODIFY SCHEDULING ORDER; DECLARATION OF MELISSA KINIYALOCTS IN SUPPORT THEREOF
The parties in the above-captioned action submit the following stipulation and order to modify the current scheduling order as follows: Current Scheduling Order Expert Disclosure Disclosure of rebuttal experts Close of Expert discovery Pretrial Conference Trial May 10, 2010 June 7, 2010 July 2, 2010 August 5, 2010 August 23, 2010 Proposed New Date August 6, 2010 September 3, 2010 September 17, 2010 October 14, 2010 November 1, 2010
S t i p u l a t i o n and Order to Modify Scheduling Order; Decl. of M e lis s a Kiniyalocts
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This Stipulation and Proposed Order is accompanied by the Declaration of Melissa Kiniyalocts attached hereto. I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document. IT IS SO STIPULATED. Dated: April 21, 2010 By: /S/ JACQUELYN K. WILSON Attorney for Evergreen School District Defendants
Dated: April 21, 2010
By:
/S/ SHANNON SMYTH-MENDOZA Attorney for City of San Jose Defendants
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M IG U E L M Á R Q U E Z A c tin g 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
Dated: April 21, 2010
By:
/S/ PETER JOHNSON
MIGUEL MÁRQUEZ Acting County Counsel Dated: April 21, 2010 By: /S/ MELISSA R. KINIYALOCTS Lead Deputy County Counsel Attorneys for County Defendants
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S t i p u l a t i o n and Order to Modify Scheduling Order; Decl. of M e lis s a Kiniyalocts
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M IG U E L M Á R Q U E Z A c tin g 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
DECLARATION OF MELISSA KINIYALOCTS IN SUPPORT OF STIPULATION AND PROPOSED ORDER TO MODIFY SCHEDULING ORDER I, Melissa Kiniyalocts, declare as follows: 1. I am employed as a Lead Deputy County Counsel for the County of Santa Clara and
am duly licensed to practice law before this Court and all California courts. I am one of the attorneys of record for the County of Santa Clara Defendants. 2. This request for an order to modify the scheduling order is made jointly pursuant to
stipulation. Counsel for all parties have met and conferred regarding the proposed expert discovery dates and trial date. 3. On December 4, 2009, Defendants' nine motions for summary judgment were heard.
The motions, which were filed by the County of Santa Clara, Evergreen School District, and City of San Jose Defendants, remain under submission. 4. The parties agree that expert discovery and trial preparation could be substantially
impacted by the rulings on the pending motions for summary judgment. Defendants are public entities and their employees. As such, prior to incurring substantial costs and fees associated with expert discovery and trial preparation, the parties agree to postpone the expert discovery deadlines and trial date to allow additional time for rulings on the pending motions. 5. The parties have previously requested modifications to the scheduling order on
January 14, 2008, May 2, 2008, September 8, 2008, January 15, 2009, and January 8, 2010. Additionally, on June 11, 2009 the Court entered a Modified Scheduling Order after a Further Case Management Conference. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 8th day of January, 2010 at San Jose, California.
/S/ MELISSA KINIYALOCTS
XXXX S t i p u l a t i o n and Proposed Order to Modify Scheduling Order; Decl. of M e lis s a Kiniyalocts
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M IG U E L M Á R Q U E Z A c tin g 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 The Court has considered the stipulation to modify the scheduling order and makes the following order pursuant to the stipulation: Expert Disclosure Disclosure of rebuttal experts Close of Expert Discovery Pretrial Conference Trial August 6, 2010 September 3, 2010 September 17, 2010 October 14, 2010, 2:00 p.m. November 1, 2010, 1:00 p.m.
IT IS SO ORDERED.
Dated:__5/___10 _________ _ 20/ __
_________________________________ HONORABLE RONALD M. WHYTE United States District Court Judge
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