Masters v. County of Santa Clara et al

Filing 38

STIPULATION AND ORDER MODIFYING CASE MANAGEMENT ORDER re 37 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 July 12, 2010. (pvtlc2, COURT STAFF) (Filed on 7/12/2010)

Masters v. County of Santa Clara et al

Doc. 38

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M IG U E L M Á R Q U E Z 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, County Counsel (S.B. #184621) 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: [phone] Facsimile: [phone] 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.

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No. 08-02473 PVT STIPULATION AND REQUEST FOR ORDER MODIFYING CASE MANAGEMENT ORDER; DECLARATION OF DAVID M. ROLLO

COME NOW THE PARTIES who have stipulated to the following request for an Order modifying the Case Management order as follows: CURRENT CASE MANAGEMENT ORDER Expert Discovery Cutoff. . . . . . July 16, 2010 Final Pretrial Conference. . . . . . August 24, 2010 2:00 p.m. Jury Trial. . . . . . . . . . . . . . . . . . . September 20, 2010 9:30 a.m. // // //
S tip u l a t io n and Request for Order M o d ify in g Case M a n a g e m e n t Order; Declaration of David M. Rollo -1 -

PROPOSED NEW DATE/ORDER August 13, 2010 Unchanged

Unchanged

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Dockets.Justia.com

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This Stipulation and proposed Order is accompanied by the Declaration of David M. Rollo attached hereto. IT IS SO STIPULATED.

Dated: July 2, 2010

By:

/S/ B. ROBERT ALLARD, Esq. Attorney for Plaintiff

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M IG U E L M Á R Q U E Z 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

I hereby attest that I have on file the holograph signature for the signature indicated by a "conformed" signature (/S/) within this e-filed document. Dated: July 2, 2010 Respectfully submitted, MIGUEL MÁRQUEZ County Counsel /S/ DAVID M. ROLLO Deputy County Counsel

ORDER The Court has considered the Stipulation to modify the Case Management Order. The Court makes the following Order pursuant to the Stipulation. The Case Management Order is modified as follows: Expert Discovery Cutoff. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . August 13, 2010 PURSUANT TO STIPULATION, IT IS SO ORDERED.

July 12, 2010 Date: _____________________

_____________________________________ MAGISTRATE PATRICIA V. TRUMBULL United State District Court Judge

S tip u l a t io n and Request for Order M o d ify in g Case M a n a g e m e n t Order; Declaration of David M. Rollo -2 -

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M IG U E L M Á R Q U E Z 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 DAVID M. ROLLO IN SUPPORT OF STIPULATION AND REQUEST FOR ORDER I, David M. Rollo, declare as follows; 1. I am employed as a 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 attorney of record for the defendants herein. 2. This request for an order modifying the Case Management Order is made jointly pursuant to stipulation. Counsel for both parties have met and conferred regarding the proposed trial date and other modified dates. 3. The parties have been working jointly to schedule depositions of expert witnesses, the majority of which are treating physicians. These health care professionals have limited availability for depositions. Counsel for plaintiff is currently on a two week vacation out of the country and will return the week of July 12. The parties need additional time to schedule and complete the depositions. 4. The parties have previously requested modifications to the Case Management Order on May 18, 2009 (Document 23), July 20, 2009 (Document 29) and October 9, 2009 (Document 33) due in part to medical reasons/leaves by defendants' counsel, and in part to plaintiff's unresolved medical condition. I declare under penalty of perjury that the foregoing is true and correct, and I executed this Declaration on July 2, 2010, at San Jose, California.

/S/ DAVID M. ROLLO

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S tip u l a t io n and Request for Order M o d ify in g Case M a n a g e m e n t Order; Declaration of David M. Rollo -3 -

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