Daniesha Washington v. County of Monterey et al

Filing 38

STIPULATION AND ORDER extending the close of fact discovery to February 1, 2013. All other deadlines remain the same. Signed by Magistrate Judge Howard R. Lloyd on December 20, 2012. (hrllc1, COURT STAFF) (Filed on 12/20/2012)

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1 2 3 4 5 Adam J. Krolikowski (SBN 202946) Jennifer A. Schwarz (SBN 253067) The Krolikowski Law Firm 1200 Main Street, Suite H Irvine, California 92614 Tel. (949) 269-1869 Fac. (949) 269-1868 email: adam usethelaw.com email: enn1 er uset e aw.com *E-FILED: December 20, 2012* 6 Attorneys for Plaintiff 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION 10 11 DANIESHA individual, WASHINGTON, an Plaintiff, 12 13 v. 14 COUNTY OF MONTEREY, a government entity; and DOES 1 to 20, mclusive, 15 16 Case No. C 12-01699 HRL Before Judge Howard R. Lloyd STIPULATION AND [PROPOSED] ORDER EXTENDING THE COURT'S FACTUAL DISCOVERY CUTOFF Defendants. 17 STIPULATION TO EXTEND THE WRITTEN DISCOVERY CUT-OFF 18 The parties to this action, through their respective attorneys of record, stipulate 19 and agree as follows: 20 The court designated cut-off date of January 14, 2013 for all factual discovery 21 shall be extended to February 1, 2013. Plaintiff has very limited availability in 22 which to provide full and complete discovery responses for Defendant. 23 Defendant needs adequate time to review and respond to the discovery responses 24 of Plaintiff. As such, parties agree that they will have until February 1, 2013 to 25 conduct all written discovery, depositions, and other factual discovery matters. 26 By this stipulation, the parties understand that other than motions related to 27 discovery, no other dates imposed by the Court's trial order are to be extended. 28 STIPULATION TO EXTEND DISCOVERY CUT-OFF NORTHERN DISTRICT-SAN JOSE DIVISION CASE NO: C 12-01699 The Krolikowski Law Firm 1 2 3 /s/Adam Krolikowski Adam J. Kiohkowsk1 for PlaintiffDaniesha Washington Dated: December 6, 2012 4 5 6 7 Dated: December 6, 2012 av1 a er or efendants County of Monterey Defendant California Forensic Medical Group 8 9 10 11 12 13 Pursuant to stipulation, it is SO ORDERED. DATED: December 20, 2012 ________________________ The Honorable Howard R. Lloyd United States Magistrate Judge 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NORTHERN DISTRICT-SAN JOSE DIVISION STIPULATION TO EXTEND CAsE No: C 12-01699 DISCOVERY CUT -OFF -2-

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