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

April 12, 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: Honorable John A. Mendez United States District Court Judge

STIPULATION TO MODIFY SCHEDULING ORDER

IT IS HEREBY STIPULATED by and between the Plaintiff, Prison Legal News a project of the Human Rights Defense Center by and through their attorney of record, Ernest Galvan of the law firm of Rosen Bien & Galvan, LLP, and Defendants County of Sacramento and Scott Jones, by and through their attorney, John Lavra of the law firm of Longyear, O'Dea & Lavra LLP, as follows:

The parties recently completed mediation on April 9, 2012. As a result of that mediation, the parties are continuing to progress towards potential settlement of this case.

In order to pursue settlement, the parties agreed at the mediation to reschedule the currently scheduled dates for disclosure of expert witnesses and expert witness reports.

On April 10, 2012, Defendants' attorney contacted the court and informed the court clerk that the parties wished to modify the scheduling order to continue the disclosure dates for expert witnesses and expert witness reports, which were scheduled for April 16, 2012 and April 30, 2012.

In response thereto, the court clerk provided dates to modify the scheduling order.

The parties believe that it is the best interest of their clients to modify the scheduling order and therefore stipulate to a modification of the scheduling order as follows:

Expert disclosure: 5/30/12;

Supplemental expert disclosure: 6/8/12;

Discovery cutoff: 8/10/12;

Dispositive motion filing: 9/19/12;

Dispositive motion hearing: 10/17/12 at 9:30 a.m.

Joint pretrial statement due: 11/23/12;

Pretrial conference: 11/30/12 at ...


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