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Fee v. State

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


September 11, 2009

SANDRA J. FEE, PLAINTIFF,
v.
STATE OF CALIFORNIA, ET AL., DEFENDANTS.

The opinion of the court was delivered by: Honorable Ronald M. Whyte United States District Judge

STIPULATION TO CONTINUE DATES FOR PRE-TRIAL DEADLINES; REQUEST FOR ORDER

The parties, Plaintiff, Sandra J. Fee, and Defendants, State of California by and through the California Highway Patrol, Officer B. Rioux, and Officer A. Voorhees, by and through their attorneys of record, hereby agree and stipulate to continue the pretrial deadlines as follows:

1. The last day for both parties to serve and file trial briefs is continued from September 9, 2009 to September 14, 2009;

2. The last day for both parties to serve and file motions in limine is continued from September 9, 2009 to September 14, 2009;

3. The last day for both parties to serve and file deposition and discovery responses is continued from September 9, 2009 to September 14, 2009;

4. The last day for both parties to serve and file proposed voir dire questions is continued from September 9, 2009 to September 14, 2009;

5. The last day for both parties to serve and file jury instructions is continued from September 9, 2009 to September 14, 2009;

6. The last day for both parties to serve and file form of verdict is continued from September 9, 2009 to September 14, 2009;

7. The last day for both parties to serve and file oppositions to motions in limine is continued from September 17, 2009 to September 18, 2009;

8. The last day for both parties to serve and file objections to the use of deposition excerpts or other discovery responses is continued from September 17, 2009 to September 18, 2009;

9. The last day for both parties to serve and file counter-designations is continued from September 17, 2009 to September 18, 2009; and

10. The last day for both parties to serve and file objections to voir dire, proposed findings, verdict forms, or to the authenticity or admissibility of any trial exhibits is continued from September 17, 2009 to September 18, 2009.

Good cause exists for the requested short continuances in that there is a pending motion for summary adjudication on September 4, 2009, the determination of which would impact the above documents one way or the other. Additionally, due to the anomalies of the calendar, the date for the parties to meet and confer is only one day before the currently scheduled date of September 9, 2009 for the filing of the documents. Also, Judge Ronald M. Whyte will be unavailable on October 6 through 9, 2009 and October 15 through 16, 2009, six of the nine days that this matter is scheduled for trial. On August 31, 2009, Plaintiff's counsel called Judge Whyte's Clerk, Jackie Lynn Garcia, to inquire about whether the trial date of October 5, 2009 will be continued due to his unavailability. Ms. Garcia is out of the office until Thursday, September 3, 2009. Plaintiff's counsel was told by Jacqueline Cruz in chambers that the parties would have to wait to hear about a trial continuance until Ms. Garcia returned to the office on September 3. The first pretrial deadline of September 9, 2009 is rapidly approaching and the parties will not have word of a continuance of the trial until September 3, 2009 at the earliest, just six days before the first pretrial deadline. Finally, the requested continuances of the pretrial deadlines will not interfere with the existing trial date of October 5, 2009, the filing and serving of the Joint Pretrial Statement on September 17, 2009 or the Pretrial Conference on September 24, 2009.

Because of the issues presented above, the parties agreed between themselves to extend the deadlines.

IT IS SO STIPULATED.

ATCHISON, BARISONE, CONDOTTI & KOVACEVICH

Dated: September 1, 2009

GEORGE J. KOVACEVICH Attorneys for Plaintiff

STATE OF CALIFORNIA, ATTORNEY GENERAL'S OFFICE

Dated: September 1, 2009

JEFFREY R. VINCENT Attorneys for Defendants

ORDER (BY STIPULATION)

GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED that:

1. The last day for both parties to serve and file trial briefs is continued from September 9, 2009 to September 14, 2009;

2. The last day for both parties to serve and file motions in limine is continued from September 9, 2009 to September 14, 2009;

3. The last day for both parties to serve and file deposition and discovery responses is continued from September 9, 2009 to September 14, 2009;

4. The last day for both parties to serve and file proposed voir dire questions is continued from September 9, 2009 to September 14, 2009;

5. The last day for both parties to serve and file jury instructions is continued from September 9, 2009 to September 14, 2009;

6. The last day for both parties to serve and file form of verdict is continued from September 9, 2009 to September 14, 2009;

7. The last day for both parties to serve and file oppositions to motions in limine is continued from September 17, 2009 to September 18, 2009;

8. The last day for both parties to serve and file objections to the use of deposition excerpts or other discovery responses is continued from September 17, 2009 to September 18, 2009;

9. The last day for both parties to serve and file counter-designations is continued from September 17, 2009 to September 18, 2009; and

10. The last day for both parties to serve and file objections to voir dire, proposed findings, verdict forms, or to the authenticity or admissibility of any trial exhibits is continued from September 17, 2009 to September 18, 2009.

*The parties are advised that the Pretrial Conference is hereby continued to November 5, 2009 at 2:00 p.m., and Trial date is continued to November 16, 2009 at 1:30 p.m.

I, George J. Kovacevich, hereby attest that the faxed signature of Jeffrey R. Vincent is affixed to 22 the original of this document and that said original document is located in the Offices of Atchison, Barisone, Condotti & Kovacevich, 333 Church Street, Santa Cruz, CA 95060.

ATCHISON, BARISONE, CONDOTTI & KOVACEVICH

Dated: September 1, 2009

GEORGE J. KOVACEVICH

20090911

© 1992-2009 VersusLaw Inc.



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