AE v. County of Tulare et al
Filing
119
STIPULATION Of The Parties Consenting To Continue Discovery Deadlines, Settlement Conference And Trial Date; And ORDER, signed by Magistrate Judge Dennis L. Beck on 6/15/2011. (Dispositive Motions filed by 4/23/2012, Expert Witness Disclosure Deadlin e: 1/20/2012, Non-Dispositive Motions filed by 3/19/2012, Jury Trial set for 9/17/2012 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill, Pretrial Conference set for 7/25/2012 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill, Settlement Conference set for 12/14/2011 at 10:00 AM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck.) (Fahrney, E)
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KATHLEEN BALES-LANGE, #094765
County Counsel for the County of Tulare
Teresa M. Saucedo, #093121
Chief Deputy County Counsel
Judy Chapman, # 169479
Deputy County Counsel
2900 West Burrel, County Civic Center
Visalia, California 93291
Phone: (559) 636-4950
Fax: (559) 737-4319
E-mail: jchapman@co.tulare.ca.us
Attorneys for Yadira Portillo, Courtney Wampler, and
CWA Felix
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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
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AE,
CASE NO. 1:09-CV-02204-LJO-DLB
Plaintiff,
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v.
COUNTY OF TULARE, et al.
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STIPULATION OF THE PARTIES
CONSENTING TO CONTINUE DISCOVERY
DEADLINES, SETTLEMENT CONFERENCE
AND TRIAL DATE; AND ORDER
Defendants.
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The undersigned parties hereby request and consent to the rescheduling of the Settlement
Conference, Discovery Deadlines and the Trial Date for the following reasons:
The plaintiff has requested and been granted authority to file a Fifth Amended Complaint, for
the purpose of naming new defendants, by June 17, 2011.
There is an appeal pending with the Ninth Circuit regarding the dismissal of Defendant,
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County of Tulare from this action. The matter has been briefed and oral argument was heard on
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April 13, 2011, however, no decision has been reached.
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A settlement conference is currently set for June 22, 2011, with the statement due by June 15,
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2011. Any attempt at settlement at this point would be futile as the parties to this action are still
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uncertain.
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A hearing on Defendants, YADIRA PORTILLO, COURTNEY WAMPLER, AND CWA
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STIPULATION OF THE PARTIES CONSENTING TO CONTINUE DISCOVERY DEADLINES, SETTLEMENT CONFERENCE
AND TRIAL DATE AND [PROPOSED] ORDER
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FELIX’s motion for leave to file and serve a Third-Party Complaint to implead former Defendant,
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FAMILY BUILDERS FOSTER CARE, INC. is set for June 17, 2011.
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Discovery in this matter has been delayed pending the outcome of these issues.
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For the foregoing reasons, the parties hereby stipulate and agree as follows:
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1. The settlement conference set for June 22, 2011, is continued to December 14, 2011.
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2. The deadline for the Expert Witness Disclosure is continued from July 22, 2011, to
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January 20, 2012.
3. The deadline for non-expert discovery is continued from August 5, 2011, to February 3,
2012.
4. The deadline for disclosure of supplemental experts is continued from August 11, 2011,
to February 10, 2012.
5. The deadline for expert discovery is continued from September 2, 2011, to March 2,
2012.
6. The deadline for filing of Non-Dispositive Motions is continued from September 26,
2011, to March 19, 2012.
7. The deadline for filing of Dispositive Motions is continued from October 24, 2011, to
April 23, 2012.
8. The deadline for hearings on Non-Dispositive Motions is continued from October 21,
2011, to April 20, 2012.
9. The deadline for hearings on Dispositive Motions is continued from December 7, 2011,
to June 6, 2012.
10. The Pre-Trial Conference currently set for January 25, 2012, is continued to July 25,
2012.
11. The Trial set to commence on March 19, 2012, is continued to September 17, 2012.
Dated: 06/07/11
(authorized via email 06/07/11)
RODRIGUEZ & ASSOCIATES
By
/s/ Charles R. Chapman
CHARLES R. CHAPMAN
Attorney for Plaintiff
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STIPULATION OF THE PARTIES CONSENTING TO CONTINUE DISCOVERY DEADLINES, SETTLEMENT CONFERENCE
AND TRIAL DATE AND [PROPOSED] ORDER
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Dated: 06/07/11
(authorized via email 06/07/11)
GORDON & REES LLP
By
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/s/ George Acero
GEORGE ACERO
Attorney for Defendants Adrian Marquez and Tulare
Youth Services Bureau, Inc.
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Dated: 06/07/11
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KATHLEEN BALES-LANGE
Tulare County Counsel
By
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Dated: 06/08/11
(authorized via email 06/08/11)
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WEST & MIYAMOTO
By
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/s/ Judy Chapman
Judy Chapman
Deputy County Counsel
Attorneys for Yadira Portillo, Courtney Wampler,
and CWA Felix
/s/ Eugene F. West
EUGENE F. WEST
Attorney for Defendant, Sandra Ceballos
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IT IS SO ORDERED.
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Dated:
/s/ Dennis
June 15, 2011
L. Beck
UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:
3b142a
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STIPULATION OF THE PARTIES CONSENTING TO CONTINUE DISCOVERY DEADLINES, SETTLEMENT CONFERENCE
AND TRIAL DATE AND [PROPOSED] ORDER
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