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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


March 13, 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: John A. Mendez Honorable John A. Mendez

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 THE PRETRIAL SCHEDULING ORDER

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, Ernest Galvan, of Rosen, Bien & Galvan, LLP, hereby submit this Stipulation and Proposed Order for Modification of the Pretrial Scheduling Order. WHEREAS the parties have agreed to mediate this matter on April 9, 2012, to avoid potentially unnecessary fees and costs while they diligently work toward a resolution of this case;

WHEREAS the parties have agreed to stay any pending discovery deadlines; WHEREAS the parties have agreed to extend the time period for expert disclosures and to complete any remaining discovery;

IT IS HEREBY STIPULATED by and between the parties that:

1. The deadline for expert disclosure be extended to April 16, 2012;

2. The deadline for supplemental expert disclosures be extended to April 30, 2012;

3. The deadline for completion of discovery be extended to May 30, 2012;

IT IS SO STIPULATED.

IT IS SO ORDERED.

UNITED STATES DISTRICT COURT JUDGE

20120313

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