Fee v. State Of California et al

Filing 27

STIPULATION AND ORDER 25 to Continue Dates for Pretrial Conference and Other Prretrial Deadlines. Jury Trial set for 7/20/2009 01:30 PM in Courtroom 6, 4th Floor, San Jose. Motion Hearing set for 6/5/2009 09:00 AM in Courtroom 6, 4th Floor, San Jose. Pretrial Conference set for 7/9/2009 02:00 PM in Courtroom 6, 4th Floor, San Jose. Signed by Judge Ronald M. Whyte on 11/24/08. (jg, COURT STAFF) (Filed on 11/25/2008)

1 George J. Kovacevich, SBN 48125 ATCHISON, BARISONE, CONDOTTI & KOVACEVICH 2 A Professional Corporation 333 Church Street 3 Santa Cruz, CA 95060 Telephone: [phone] [phone] 4 Facsimile: 5 Attorneys for Plaintiff SANDRA J. FEE 6 7 EDMUND G. BROWN JR. Attorney General of the State of California 8 TYLER B. PON Supervising Deputy Attorney General 9 JEFFREY R. VINCENT, SBN 161013 10 Deputy Attorney General 1515 Clay Street, 20th Floor 11 P.O. Box 70550 *E-FILED - 11/25/08* Oakland, CA 94612-0550 12 Telephone: [phone] Fax: [phone] Email: [e-mail] 14 Attorneys for Defendants State of California by and 15 through the California Highway Patrol, Officer B. Rioux and Officer A. Voorhees 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA 18 19 20 21 SANDRA J. FEE, vs. Plaintiff, CASE NO. C08-01549-RMW STIPULATION TO CONTINUE DATES FOR PRE-TRIAL CONFERENCE AND OTHER PRETRIAL DEADLINES; REQUEST FOR ORDER

22 STATE OF CALIFORNIA, et al., 23 24 25 Defendants.

The parties, Plaintiff, Sandra J. Fee, and Defendants, State of California by and through the

26 California Highway Patrol, Officer B. Rioux, and Officer A. Voorhees, by and through their attorneys of 27 record, hereby agree and stipulate to continue the dates for the Pre-Trial Conference and other pre-trial 28 deadlines as follows:
-1STIPULATION TO CONTINUE DATES FOR PRE-TRIAL CONFERENCE AND OTHER PRE-TRIAL DEADLINES; REQUEST FOR ORDER

1

1.

The date for the completion of all non-expert discovery is continued from November 26,

2 2008 to February 26, 2009; 3 2. The last day for both parties to disclose expert witness testimony and reports is continued

4 from December 15, 2008 to March 6, 2009; 5 3. The deadline for all discovery of expert witnesses is continued from January 30, 2009 to

6 April 30, 2009; 7 4. The deadline for hearing of all pretrial motions is continued from March 6, 2009 to June

8 4, 2009; 9 10 2009; 11 12 13 6. 7. The Pre-Trial Conference is continued from April 9, 2009 to July 8, 2009; and The trial is continued from April 20, 2009 to July 20, 2009. 5. The filing of the Joint Pre-Trial Statement is continued from April 3, 2009 to July 2,

Good cause exists for the requested continuances in that the parties have had scheduling conflicts

14 that have interfered with their ability to meet the deadlines as they were previously set by the court. The 15 parties have been continuing discussions in good faith and need the additional time to complete 16 discovery in order to facilitate any possibility of settling the case short of trial. 17 18 19 20 Dated: October 28, 2008 21 22 23 24 25 Dated: October 31, 2008 26 27 /// 28 ///
-2STIPULATION TO CONTINUE DATES FOR PRE-TRIAL CONFERENCE AND OTHER PRE-TRIAL DEADLINES; REQUEST FOR ORDER

IT IS SO STIPULATED. ATCHISON, BARISONE, CONDOTTI & KOVACEVICH By: ____________/S/________________________ GEORGE J. KOVACEVICH Attorneys for Plaintiff

STATE OF CALIFORNIA, ATTORNEY GENERAL'S OFFICE By: ____________/S/________________________ JEFFREY R. VINCENT Attorneys for Defendants

1 2 3

ORDER (BY STIPULATION) GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED that: 1. The date for the completion of all non-expert discovery is continued from November 26,

4 2008 to February 26, 2009; 5 2. The last day for both parties to disclose expert witness testimony and reports is continued

6 from December 15, 2008 to March 6, 2009; 7 3. The deadline for all discovery of expert witnesses is continued from January 30, 2009 to

8 April 30, 2009; 9 4. The deadline for hearing of all pretrial motions is continued from March 6, 2009 to June

10 5, 2009; 11 12 2009; 13 14 15 6. 7. The Pre-Trial Conference is continued from April 9, 2009 to July 9, 2009; and The trial is continued from April 20, 2009 to July 20, 2009. 5. The filing of the Joint Pre-Trial Statement is continued from April 3, 2009 to July 2,

11/24/08 16 Dated: ____________________
17 18 19

__________________________________________ HONORABLE RONALD M. WHYTE UNITED STATES DISTRICT JUDGE

I, George J. Kovacevich, hereby attest that the faxed signature of Jeffrey R. Vincent is affixed to

20 the original of this document and that said original document is located in the Offices of Atchison, 21 Barisone, Condotti & Kovacevich, 333 Church Street, Santa Cruz, CA 95060. 22 23 24 Dated: November 5, 2008 25 26 27 28
-3STIPULATION TO CONTINUE DATES FOR PRE-TRIAL CONFERENCE AND OTHER PRE-TRIAL DEADLINES; REQUEST FOR ORDER

ATCHISON, BARISONE, CONDOTTI & KOVACEVICH By: ____________/S/________________________ GEORGE J. KOVACEVICH