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Prison Legal New, A Project of the v. County of Sacramento; Scott R.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


February 1, 2012

PRISON LEGAL NEW, A PROJECT OF THE
HUMAN RIGHTS DEFENSE CENTER PLAINTIFF,
v.
COUNTY OF SACRAMENTO; SCOTT R. JONES, INDIVIDUALLY AND IN HIS CAPACITY AS SHERIFF OF THE COUNTY OF SACRAMENTO; DOES 1-20, IN THEIR INDIVIDUAL AND OFFICIAL CAPACITIES,
DEFENDANT

The opinion of the court was delivered by: The Honorable John A. Mendez United States District Court Judge

LONGYEAR, O'DEA & LAVRA, LLP John A. Lavra, CSB No.: 114533 Jeri L. Pappone, CSB No.: 210104 Amanda L. Butts, CSB No.: 253651 3620 American River Drive, Suite 230 Sacramento, CA 95864 Phone: 916-974-8500 Facsimile: 916-974-8510 Attorneys for County of Sacramento and Scott R. Jones SANFORD JAY ROSEN -- 62566 ERNEST GALVAN -- 196065 KENNETH WALCZAK -- 247389 ROSEN, BIEN & GALVAN, LLP 315 Montgomery Street, Tenth Floor San Francisco, California 94104-1823 Telephone: (415) 433-6830 Facsimile: (415) 433-7104 Email: kwalczak@rbg-law.com LANCE WEBER HUMAN RIGHTS DEFENSE CENTER P.O. Box 2420 Brattleboro, Vermont 05303-2420 Telephone: (802) 257-1342 Facsimile: (866) 735-7136 Email: lweber@humanrightsdefensecenter.org Attorneys for Plaintiff

STIPULATION AND ORDER TO MODIFY HEARING ON PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION

Defendants COUNTY OF SACRAMENTO and SCOTT JONES (collectively hereafter "Defendants"), by and through their attorney of record, John Lavra, of Longyear, O'Dea & Lavra, LLP, and Plaintiff PRISON LEGAL NEWS, by and through its attorney of record, Kenneth Walczak, of Rosen, Bien & Galvan, LLP, hereby submit this Stipulation and Proposed Order for Modification of the hearing date on Plaintiff's Motion for Preliminary Injunction. Due to the complicated nature of the issues involved in this matter and the current demands of counsel's calendar, Defendants require additional time to respond to Plaintiff's motion.

As a result, the parties stipulate to modify the hearing date on Plaintiff's Motion for Preliminary Injunction. The motion is presently scheduled to be heard on February 22, 2012, at 9:30 a.m. The parties agree to move the hearing to March 7, 2012, at 9:30 a.m. The parties additionally agree that Defendants will file their response to Plaintiff's Motion to Preliminary Injunction on or before February 15, 2012, and that Plaintiff will file any reply brief on or before February 29, 2012.

IT IS HEREBY STIPULATED by and between the parties:

1. Plaintiff's Motion for Preliminary Injunction will be heard on March 7, 2012, at 9:30 a.m. in Courtroom 6 of the United States District Court, Eastern District of California, before Honorable Judge John A. Mendez;

2. Defendants will file and serve their response to Plaintiff's Motion for Preliminary Injunction on or before February 15, 2012; and

3. Plaintiff will file and serve any reply brief on or before February 29, 2012.

IT IS SO STIPULATED.

IT IS SO ORDERED.

John A. Mendez

20120201

© 1992-2012 VersusLaw Inc.



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