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Meagan Buckholtz, Personally v. Santa Clara County
May 2, 2011
MEAGAN BUCKHOLTZ, PERSONALLY,
SANTA CLARA COUNTY, ET AL. DEFENDANTS.
The opinion of the court was delivered by: Judge: Judge Susan Illston
MIGUEL MARQUEZ, County Counsel (S.B. #184621) MARK F. BERNAL, Deputy County Counsel (S.B. #173923) OFFICE OF THE COUNTY COUNSEL 70 West Hedding, East Wing, 9th Floor San Jose, California 95110-1770 Telephone: (408) 299-5900 E DIST Facsimile: (408) 292-7240 A CT T S RI S T C Attorneys for Defendants D U COUNTY OF SANTA CLARA, SUSAN E R O T T WARE, KAREN HEGGIE, DONALD I Submitting counsel are GAGE, LIZ KNISS, MICHAEL ROSSI, N 7 FRAN ALLEN, JONATHAN U directed to serve this A I WEINBERG, WILL LIGHTBOURNE, order upon all other N KATHLEEN MILES, IZI CHAN, N non-efiling parties R PATRICIA GEISICK (ALSO SUED O in this action. O ERRONEOUSLY HEREIN AS "SANTA T I CLARA COUNTY DEPARTMENT OF H L R F E A C SOCIAL SERVICES" AND R "DEPARTMENT OF FAMILIES AND N F DI O CHILDREN SERVICES AGENCY") STRICT
SUPPLEMENTAL CASE MANAGEMENT
STATEMENT AND [PROPOSED] ORDER
CONTINUING CASE MANAGEMENT ) CONFERENCE
Date: May 6, 2011
Time: 3:00 p.m.
Dept.: Crtrm 10, 19th Floor
Pursuant to Civil L.R. 16-10(d), the parties to the above-entitled
action certify that they
met and conferred prior to the subsequent case management
conference scheduled in this case 25 and jointly submit this
Supplemental Case Management Statement and Proposed Order
Continuing Case Management Conference and request the Court to adopt
it as a Supplemental
Case Management Order in this case.
C county Counsel C county of Santa Clara
DESCRIPTION OF SUBSEQUENT CASE DEVELOPMENTS
The following progress or changes have occurred since the last case
statement filed by the parties, and necessitate a further
continuance of the currently scheduled 4 conference: 5
1. This Court continued the prior Case Management Conference because
delays in the Santa Clara County Superior Court's release of
Plaintiff's Child Dependency 7 records pursuant to Defendants' Welfare
& Institutions Code §827 petition.
On or about January 24, 2011, the Superior Court did release some, but
not all, categories
of the requested records. As a result, Defendants were required to
submit a second Welfare &
Institutions Code §827 petition for the missing records on or about
February 11, 2011.
Earlier this week, counsel for Defendants learned from the Superior
Court that the records
responsive to the second petition will not be ready for release for
another three to four weeks.
The parties respectfully request that the Subsequent Case Management
continued approximately 90 days for the following reasons:
A. Plaintiff's Child Dependency records are necessary for Defendants to prepare for the deposition of Plaintiff and to then present, and for Plaintiff to oppose, a summary judgment motion;
B. The parties will require time to review and analyze the second set of released Child Dependency records to determine if they are fully responsive to the Welfare & Institutions Code §827 petition, or whether a further petition will be needed.
2. The parties jointly request the Court to make the following Supplemental Case Management Order:
The subsequent case management conference scheduled for 3:00 pm on May 6, 2011, in Courtroom 10 be continued to 3:00 pm on ...
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