Mitchell et al v. County of Madera et al
Filing
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STIPULATION and ORDER re limited extension of non-expert discovery. Order signed by Magistrate Judge Dennis L. Beck on 6/24/2011. (Hernandez, M)
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DENNIS M. COTA, Bar No. 127992
CAROLYN J. FRANK, Bar No. 245479
JAMES D. MAYNARD, Bar No. 244844
COTA COLE LLP
2261 Lava Ridge Court
Roseville, CA 95661
Telephone:
(916) 780-9009
Facsimile:
(916) 780-9050
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Attorneys for Defendants
COUNTY OF MADERA and
MICHAEL KEITZ
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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KAREN MITCHELL and TONI LINDSEY,
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Plaintiffs,
Case No. 1:10-cv-01405-LJO-DLB
STIPULATION RE LIMITED
EXTENSION OF NON-EXPERT
DISCOVERY
v.
COUNTY OF MADERA and MICHAEL
KEITZ,
Defendants.
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{DMC/00016477.}
STIP RE LTD EXT OF NON-EXPERT DISCOVERY
Case No. 1:10-cv-01405-LJO-DLB
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IT IS HEREBY STIPULATED by and between the above-entitled parties through their
respective attorneys of record that:
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1.
The Scheduling Order in the above-entitled matter dated December 2, 2010, set
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forth that all discovery pertaining to non-experts was to be completed on or before July 1, 2011.
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Notwithstanding the parties' diligent efforts to complete the depositions of all non-expert
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witnesses in advance of the scheduled deadline, unanticipated schedule conflicts, vacations, and
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health issues have necessitated rescheduling of the following depositions to dates beyond the
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July 1, 2011 deadline.
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2.
Depositions to be taken outside the non-expert discovery deadline should be
limited to the following:
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Karen Mitchell
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Ernie LiCalsi
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Kathy Taylor
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Michael Keitz
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Depositions of those individuals designated as Persons Most
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Knowledgeable in response to two deposition notices served by Plaintiffs
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on June 21, 2011
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3.
No other non-expert discovery will be taken past July 1, 2011. Should the
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depositions of the above-listed individuals cause the need for discovery-related motions, the
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August 1, 2011 deadline for filing such motions, and the August 26, 2011 deadline for hearing
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discovery motions related to these four witnesses shall be extended to September 1, 2011 for
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filing and September 23, 2011 for hearing.
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4.
Nothing about the continued deposition dates herein stipulated to by the parties
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shall affect the ability of the parties to proceed with the currently scheduled Pretrial Conference
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on November 30, 2011 or the scheduled trial date of January 17, 2012.
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///
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///
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///
{DMC/00016477.}
STIP RE LTD EXT OF NON-EXPERT DISCOVERY
Case No. 1:10-cv-01405-LJO-DLB
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IT IS SO STIPULATED.
Dated: June 23, 2011
COTA COLE LLP
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By: /s/ Dennis M. Cota
Dennis M. Cota
Carolyn J. Frank
James D. Maynard
Attorneys for Defendants
COUNTY OF MADERA and MICHAEL
KEITZ
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Dated: June 23, 2011
PENNER, BRADLEY & SIMONIAN
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By: /s/ Peter S. Bradley
Peter S. Bradley
Attorneys for Plaintiffs
KAREN MITCHELL and TONI
LINDSEY
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ORDER
Based on the Stipulation set forth above, the accompanying Declaration of Dennis M.
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Cota, and the absence of any impact on the Pretrial Conference and trial dates in this matter, good
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cause exists for the limited extension of discovery agreed to by the parties, and therefore,
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IT IS SO ORDERED.
Dated:
/s/ Dennis
June 24, 2011
L. Beck
UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:
3b142a
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{DMC/00016477.}
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STIP RE LTD EXT OF NON-EXPERT DISCOVERY
Case No. 1:10-cv-01405-LJO-DLB
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