Jackson et al v. Oak Grove School District et al
Filing
216
STIPULATION AND ORDER TO CONTINUE DEADLINES FOR DISPOSITIVE MOTIONS AND TO EXTEND DISCOVERY re 214 STIPULATION WITH PROPOSED ORDER filed by J.J. Last Day to Hear Dispositive Motions: 10/29/2012. Signed by Chief Judge James Ware on August 20, 2012. (wsn, COURT STAFF) (Filed on 8/20/2012)
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Attorneys for Defendants
OAK GROVE SCHOOL DISTRICT,
MANNY BARBARA, KATHERINE
BAKER, RICHARD HOLTERMANN,
TAMARA UNCK, RISA QUON, NANCY
LETTENBERGER, JACQUELINE
ADAMS, JEREMY NISHIHARA,
DIANNE LEMKE and DENNIS
HAWKINS
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IT IS S
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MARK E. DAVIS—BAR NO.79936
DAVIS & YOUNG, APLC
1960 The Alameda, Suite 210
San Jose, CA 95126
Phone: 408.244.2166
Fax:
408.244.7815
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.71802
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UNITED STATES DISTRICT COURT
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IN AND FOR THE STATE OF CALIFORNIA
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NORTHERN DISTRICT
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J.J., a minor, by and through his
Guardian ad litem, Robert M. Vantress,
Plaintiff,
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No. C 08 05376 JW
STIPULATION AND ORDER TO CONTINUE
DEADLINES FOR DISPOSITIVE MOTIONS
AND TO EXTEND DISCOVERY
vs.
OAK GROVE SCHOOL DISTRICT, a
public entity school district, et al.,
Complaint Filed:
Trial Date: TBD:
November 26, 2008
Defendants.
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IT IS HEREBY STIPULATED, pursuant to Civil Local Rule 6-2, between Plaintiff
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J.J., a minor, by and through his appointed Guardian ad Litem, Robert M. Vantress and
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counsel for Defendants Oak Grove School District, Manny Barbara, Katherine Baker,
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Richard Holtermann, Tamara Unck, Risa Quon, Nancy Lettenberger, Jacqueline Adams,
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{71802/00176261-1}
-1Stip & Order To Cont. Defs OGSD, M. Barbara, K. Baker, R. Holtermann, T. Unck, R. Quon, N. Lettenberger, J. Adams, J.Nishihara, D.
Lemke & D. Hawkins’ & Deanna Mouser & Atkinson, Andelson, Loya, Ruud & Romo’s Dispositive Motions
.71802
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Jeremy Nishihara, Dianne Lemke and Dennis Hawkins, and counsel for Defendants
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Deanna Mouser and Atkinson, Andelson, Loya, Ruud & Romo, that:
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1.
The court ordered last day for hearing on dispositive motions for any party is
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currently set for September 24, 2012, (Document200), which is impractical now given that
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discovery is not complete, and given the retirement of Judge Ware from the case and the
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absence of a reassignment of this case to a new judge. So that such motions can be
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heard on regular notice, and discovery may be completed, the parties hereby stipulate that
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said motion be noticed in accordance with the Civil Local Rules of this Court and that that
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the hearing date be continued from September 24, 2012, to October 29, 2012, or until such
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date as the newly assigned judge may schedule, or thereafter, as set forth below, and that
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said motion be noticed in accordance with the new hearing date.
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2.
The new deadline for the hearing of such dispositive motions shall be further
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extended if, by the deadline for filing and service of such motions, the case has not been
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reassigned. If the case has not been reassigned by that time, the deadline to file and
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serve such motions shall be on the 30th calendar day following notice of the reassignment
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of this case, or the first date following such date when filing and service is required by the
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deadline for such motions required by the Court after reassignment, whichever is later. The
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parties hereto stipulate to cooperate with each other to seek a reassignment of this case at
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the earliest time for the convenience of the Court.
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3.
The parties have been involved in numerous depositions of the relevant
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parties and witnesses in this case. However, because of calendaring conflicts, vacations,
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and /or the inability to complete certain depositions on the scheduled date or disputes as to
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the deposition of Defendant Deanna Mouser, the parties have not been able to complete
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all of the depositions that had previously been scheduled. All parties agree that it will be
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necessary to complete these depositions before dispositive motions can be filed and the
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parties stipulate to extend discovery to complete discovery which has already been
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initiated or noticed. The foregoing agreement to extend the deadline for filing, serving, and
{71802/00176261-1}
-2Stip & Order To Cont. Defs OGSD, M. Barbara, K. Baker, R. Holtermann, T. Unck, R. Quon, N. Lettenberger, J. Adams, J.Nishihara, D.
Lemke & D. Hawkins’ & Deanna Mouser & Atkinson, Andelson, Loya, Ruud & Romo’s Dispositive Motions
.71802
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hearing dispositive motions is not and is not to be construed to be a waiver of any objection
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to any notice of deposition or to any demand for production of documents.
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4.
The court recently vacated the Preliminary Pretrial Conference set for June
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25, 2012, (Document209) and has not reset the Preliminary Pretrial Conference pending
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the filing of defendants’ dispositive motions. Therefore, no party will be prejudiced by the
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short continuance of the hearing on and filing of defendants’ dispositive motions.
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THEREFORE, the parties agree and stipulate, through their respective counsel, as
set forth above.
IT IS SO STIPULATED.
DATED: August 17, 2012
VANTRESS LAW GROUP
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By
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/s/
Robert M. Vantress
Attorneys for Plaintiff
J.J., a minor
DATED: August 17, 2012
DAVIS & YOUNG, APLC
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By
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/s/
Mark E. Davis
Attorneys for Defendants
OAK GROVE SCHOOL DISTRICT,
MANNY BARBARA, KATHERINE
BAKER, RICHARD HOLTERMANN,
TAMARA UNCK, RISA QUON,
NANCY LETTENBERGER,
JACQUELINE ADAMS, JEREMY
NISHIHARA, DIANNE LEMKE and
DENNIS HAWKINS
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{71802/00176261-1}
-3Stip & Order To Cont. Defs OGSD, M. Barbara, K. Baker, R. Holtermann, T. Unck, R. Quon, N. Lettenberger, J. Adams, J.Nishihara, D.
Lemke & D. Hawkins’ & Deanna Mouser & Atkinson, Andelson, Loya, Ruud & Romo’s Dispositive Motions
.71802
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DATED: August 17, 2012
ATKINSON, ANDELSON, LOYA, et al.
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By /s/
Christopher Andre
Attorneys for Defendants
DEANNA J. MOUSER and
ATKINSON, ANDELSON, LOYA,
RUUD & ROMO
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ORDER
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATED: August 20, 2012
BY: __________________________________
JAMES WARE
HONORABLE ___________________
UNITED STATES DISTRICT JUDGE
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{71802/00176261-1}
-4Stip & Order To Cont. Defs OGSD, M. Barbara, K. Baker, R. Holtermann, T. Unck, R. Quon, N. Lettenberger, J. Adams, J.Nishihara, D.
Lemke & D. Hawkins’ & Deanna Mouser & Atkinson, Andelson, Loya, Ruud & Romo’s Dispositive Motions
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