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John Allen Rainwater v. County of Sacramento

October 4, 2011

JOHN ALLEN RAINWATER,
PLAINTIFF,
v.
COUNTY OF SACRAMENTO, JOHN MCGINNISS, IN HIS INDIVIDUAL AND OFFICIAL CAPACITIES AS SHERIFF OF SACRAMENTO COUNTY, AND DOES 1 THROUGH 50 IN THEIR INDIVIDUAL JUDGE: MAGISTRATE JUDGE AND OFFICIAL CAPACITIES, GREGORY G. HOLLOWS DEFENDANTS.



The opinion of the court was delivered by: Hon. Gregory G. Hollows

A PROFESSIONAL CORPORATION David A. Melton, SBN 176340 Colleen R. Howard, SBN 257661 350 University Ave., Suite 200 Sacramento, California 95825 TEL: 916.929.1481 FAX: 916.927.3706 Attorneys for Defendants JOHN McGINNESS and COUNTY OF SACRAMENTO

STIPULATION TO MODIFY THE DISCOVERY AND SCHEDULING ORDER

Complaint Filed: January 4, 2011

The parties, by and through their counsel of record, request that the Court modify the Discovery and Scheduling Order filed on July 1, 2011 (Docket No. 16), for the good cause set forth in this Stipulation.

On July 1, 2011, this Court issued a Discovery and Scheduling Order (Docket No. 16), which set the last day to complete all discovery on October 14, 2011. the parties have diligently participated in discovery of this case. However, due to defense counsel's unavailability, it is not {00940275.DOCX} 1 possible for defense counsel to travel to Coalinga to take plaintiff's deposition prior to October 14, 2011.

Additionally, plaintiff met and conferred with defense counsel regarding inadvertently omitted pages from defendant JOHN MCGINNESS' responses to plaintiff's Request for Production. Plaintiff has also asked defense counsel to indicate which documents are responsive to the specific requests made.

After meeting and conferring, the parties now stipulate to continuing discovery until November 7, 2011 for the limited purpose of permitting defense counsel enough time to take plaintiff's deposition, and to provide defense counsel with time to comply with plaintiff's meet and confer requests as outlined above.

IT IS SO STIPULATED.

IT IS SO ORDERED.

Gregory G. Hollows

20111004

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