Daniesha Washington v. County of Monterey et al

Filing 40

STIPULATION AND ORDER continuing the close of fact discovery to February 28, 2013. The Court is not inclined to grant any further extensions. Signed by Magistrate Judge Howard R. Lloyd on January 29, 2013. (hrllc1, COURT STAFF) (Filed on 1/29/2013)

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Adam J. Krolikowski (SBN 202946)
THE KROLIKOWSKI LAW FIRM
1200 Main Street, Suite H
Irvine, California 92614
T. [phone]
F. [phone]
Email: [e-mail]
Attorneys for Plaintiff

*E-FILED: January 29, 2013*

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

THE KROLIKOWSKI LAW FIRM
1200 Main Street, Suite H
Irvine, CA 92614

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DANIESHA WASHINGTON, an
individual,

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Plaintiff,
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vs.
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COUNTY OF MONTEREY, a
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government entity; CALIFORNIA
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FORENSIC MEDICAL GROUP, an )
business entity unknown; and DOES 2 )
to 20, inclusive,
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Defendants. )

Case No.: Case No. C 12-01699 HRL
Before the Hon. Howard R. Lloyd
STIPULATION AND [PROPOSED]
ORDER TO FURTHER EXTEND
THE FACTUAL DISCOVERY
CUTOFF DATE OF FEBRUARY 1,
2013; DECLARATION OF
JENNIFER A. SCHWARZ

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STIPULATION TO EXTEND THE FACTUAL DISCOVERY CUT-OFF

The parties to this action, through their respective attorneys of record,
stipulate and agree as follows:

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STIPULATION AND [PROPOSED] ORDER TO FURTHER EXTEND THE FACTUAL
DISCOVERY CUTOFF DATE OF FEBRUARY 1, 2013; DECLARATION OF
JENNIFER A. SCHWARZ
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The court designated cut-off date was extended per stipulation of the parties

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to February 1, 2013. The parties request that the Discovery cut-off now be
extended to February 28, 2013, as depositions for Defendants witnesses are not
able to be taken prior to the February 1, 2013 cut-off. As such, parties agree that

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they will have until February 28, 2013 to conduct all depositions and other factual
discovery matters. By this stipulation, the parties understand that other than

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THE KROLIKOWSKI LAW FIRM
1200 Main Street, Suite H
Irvine, CA 92614

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motions related to discovery, no other dates imposed by the Court’s trial order are
to be extended.

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The Krolikowski Law Firm

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Dated: January 25, 2013

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/s/Adam Krolikowski
Adam J. Krolikowski for
Plaintiff Daniesha Washington

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Craddick, Candland, & Conti

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Dated: January 25, 2013

_/s/_____________________
W. David Walker for
Defendants County of Monterey
and California Forensic Medical
Group

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STIPULATION AND [PROPOSED] ORDER TO FURTHER EXTEND THE FACTUAL
DISCOVERY CUTOFF DATE OF FEBRUARY 1, 2013; DECLARATION OF
JENNIFER A. SCHWARZ
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[PROPOSED] ORDER

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GOOD CAUSE HAVING BEEN SHOWN,
The factual discovery cutoff date of February 1, 2013 shall be extended to

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February 28, 2013.
Having already granted a previous request for an extension of the discovery schedule, the
Court is not inclined to grant any further extensions.

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Date: January 29, 2013

___________________________

THE KROLIKOWSKI LAW FIRM
1200 Main Street, Suite H
Irvine, CA 92614

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Honorable Howard K. Lloyd

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Honorable Howard R. Lloyd

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STIPULATION AND [PROPOSED] ORDER TO FURTHER EXTEND THE FACTUAL
DISCOVERY CUTOFF DATE OF FEBRUARY 1, 2013; DECLARATION OF
JENNIFER A. SCHWARZ
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