Mitchell v. County Of Monterey

Filing 89

STIPULATION AND ORDER Granting Request to File Separate Statement in Support of Motions for Summary Judgment/Summary Adjudication re 88 Stipulation. Signed by Judge James Ware on 12/16/2010. (ecg, COURT STAFF) (Filed on 12/16/2010)

Mitchell v. County Of Monterey

Doc. 89

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DAVID P. MASTAGNI, ESQ. (SBN 57721) DAVID E. MASTAGNI, ESQ. (SBN 204244) JAMES B. CARR, ESQ. (SBN 53274) ISAAC S. STEVENS, ESQ. (SBN 251245) MASTAGNI, HOLSTEDT, AMICK, MILLER & JOHNSEN A Professional Corporation 1912 "I" Street Sacramento, California 95811-3151 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

DANIEL J. MITCHELL, et al., v. Plaintiffs,

COUNTY OF MONTEREY, Defendant.

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Case No.: 5: 08-01166 JW STIPULATION REGARDING SEPARATE STATEMENT IN SUPPORT OF MOTIONS FOR SUMMARY JUDGMENT/SUMMARY ADJUDICATION

WHEREAS, this action involves twenty plaintiffs and the defendant has asserted nineteen affirmative defenses; WHEREAS, the parties have conducted thirty depositions and produced thousands of pages of documentary evidence during the course of discovery; WHEREAS, the parties believe filing separate statements on undisputed facts will enhance the clarity of the parties' moving papers and allow the Court to quickly identify and locate the evidence the parties rely on in their motions, NOW, THEREFORE, it is hereby stipulated, between the parties, and each of them, that:they request that the court issue an order allowing them to file a separate statement of undisputed facts in
STIPULATION REGARDING ADMISSIBILITY OF EVIDENCE Mitchell v. County of Monterey Northern District Case No. C08-01166 JW

Dockets.Justia.com

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support of their motions for summary judgment/summary adjudication, should they deem it necessary, IT IS SO STIPULATED.

Dated: December 15, 2010

MASTAGNI, HOLSTEDT, AMICK, MILLER & JOHNSEN

By:

/s/ Isaac S. Stevens ISAAC S. STEVENS Attorneys for Plaintiffs DAN MITCHELL, et al. /s/ William K. Rentz WILLIAM K. RENTZ Sr. Deputy County Counsel Attorney for Defendant COUNTY OF MONTEREY

Dated: December 15, 2010

By:

STIPULATION REGARDING ADMISSIBILITY OF EVIDENCE

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Mitchell v. County of Monterey Northern District Case No. C08-01166 JW

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[PROPOSED] ORDER FOR LEAVE TO FILE A SEPARATE STATEMENT

The Court hereby GRANTS the parties leave to file separate statements of undisputed facts in support of their motions for summary judgment/summary adjudication.

IT IS SO ORDERED

16 Dated: December ____, 2010

________________________________ Hon. James Ware

STIPULATION REGARDING ADMISSIBILITY OF EVIDENCE

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Mitchell v. County of Monterey Northern District Case No. C08-01166 JW