Fee v. State Of California et al

Filing 52

STIPULATION AND ORDER 51 to Continue Dates for Pretrial Deadlines. Signed by Judge Ronald M. Whyte on 3/5/09. (jg, COURT STAFF) (Filed on 3/5/2009)

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 Oakland, CA 94612-0550 12 Telephone: [phone] Fax: [phone] Email: [e-mail] 14 *E-FILED - 3/5/09* 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 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 DEADLINES; REQUEST FOR ORDER

1

1.

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

2 2009 to March 20, 2009; 3 2. The last day for both parties to disclose expert witness testimony and reports is continued

4 from March 6, 2009 to March 20, 2009. 5 Good cause exists for the requested continuances in that the parties have had scheduling conflicts

6 that have interfered with their ability to meet the deadlines as they were previously set by the court. In 7 addition, the parties informally agreed to extend these deadlines in view of intervening motions before 8 the court which would have had bearing on these particular deadlines. Those motions were to be heard 9 immediately before and after the current deadlines. Because of the conflation of the deadline with the 10 hearings on the motions, the parties agreed between themselves to extend the deadlines. In reliance on 11 that understanding, Plaintiff cancelled the depositions of the officers which had been noticed for 12 February 25 and 26, 2009. 13 14 15 16 Dated: March 3, 2009 17 18 19 20 21 Dated: March 3, 2009 22 23 /// 24 /// 25 /// 26 /// 27 /// 28 ///
-2STIPULATION TO CONTINUE DATES FOR 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 February 26,

4 2009 to March 20, 2009; 5 2. The last day for both parties to disclose expert witness testimony and reports is continued

6 from March 6, 2009 to March 20, 2009. 7

3/5/09 8 Dated: ____________________
9 10 11

__________________________________________ 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

12 the original of this document and that said original document is located in the Offices of Atchison, 13 Barisone, Condotti & Kovacevich, 333 Church Street, Santa Cruz, CA 95060. 14 15 16 Dated: March 3, 2009 17 18 19 20 21 22 23 24 25 26 27 28
-3STIPULATION TO CONTINUE DATES FOR PRE-TRIAL DEADLINES; REQUEST FOR ORDER

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