Masters v. County of Santa Clara et al

Filing 17

STIPULATION AND ORDER EXTENDING DEADLINE FOR EARLY NEUTRAL EVALUATION (ENE) re 16 Stipulation, filed by Deputy Rogers, Deputy Anderson, Deputy Eng, Santa Clara County Sheriff's Department, County of Santa Clara. Signed by Judge Patricia V. Trumbull on December 5, 2008. (pvtlc2, COURT STAFF) (Filed on 12/5/2008)

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Case 5:08-cv-02473-PVT Document 16 Filed 12/04/2008 Page 1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 nta C l a r a S a n Jose , Ca l i fo r n i a ANN MILLER RAVEL, County Counsel (S.B. #62139) DAVID M. ROLLO, Deputy County Counsel (S.B. #111998) 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, SANTA CLARA COUNTY SHERIFF'S DEPARTMENT, DEPUTY ENG, DEPUTY ANDERSON AND DEPUTY ROGERS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (SAN JOSE) NICK MASTERS, Plaintiff, v. COUNTY OF SANTA CLARA, et al., Defendants. ) ) ) ) ) ) ) ) ) ) No. 0802473 PVT XXXXXXXXXX STIPULATION AND PROPOSED ORDER EXTENDING DEADLINE FOR EARLY NEUTRAL EVALUATION (ENE) (ADR Local Rule 5.5) COME NOW THE PARTIES who have stipulated to the following request for an Order extending the deadline by which this matter may be subject to an Early Neutral Evaluation (hereinafter "ENE") to and including Friday, February 27, 2009. CASE STATUS/REQUEST This case was referred to the ENE process on September 2, 2008 following the initial Case Management Conference. Since that referral, the parties have been exchanging information in good faith in lieu of formal discovery. Unfortunately, counsel for both sides have had numerous calendar conflicts with regard to availability for depositions and formal compliance with all ENE requirements. Counsel agree that the current ENE deadline needs to be extended to allow for an orderly progression of discovery and preparation for a meaningful ENE process. This is the first such request in this matter. Counsel do not anticipate that the S tip u la tio n and [Proposed] Order Extending D e a d lin e for Early Neutral Evaluation (ENE) -1 - 0 8 0 2 4 7 3 PVT Case 5:08-cv-02473-PVT Document 16 Filed 12/04/2008 Page 2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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 nta C l a r a S a n Jose , Ca l i fo r n i a requested extension will impact any other case management dates set forth in the Case Management Order. Dated: December 4, 2008 By: /S/ B. ROBERT ALLARD, ESQ. At torney for Plaintiff NICK MASTERS I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature ( /S/ ) within this e-filed document. Dated: December 4, 2008 Respectfully submitted, ANN MILLER RAVEL County Counsel By: /S/ DAVID M. ROLLO Deputy County Counsel Attorneys for Defendants COUNTY OF SANTA CLARA, SANTA CLARA COUNTY SHERIFF'S DEPARTMENT, DEPUTY ENG, DEPUTY ANDERSON AND DEPUTY ROGERS ORDER The Court has considered the Stipulation to extend the deadline by which this matter be subject to an Early Neutral Evaluation and makes the following Order: the deadline by which the ENE process be completed is extended to February 27, 2009. PURSUANT TO STIPULATION, IT IS SO ORDERED. December 5, 2008 Date: __________________ _____________________________________ MAGISTRATE PATRICIA V. TRUMBULL United States District Court Judge 157027.wpd S tip u la tio n and [Proposed] Order Extending D e a d lin e for Early Neutral Evaluation (ENE) -2 - 0 8 0 2 4 7 3 PVT

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