FORREST BLOCKER, individually and as Guardian Ad Litem for her minor child, M.B., Plaintiffs,
COUNTY OF CONTRA COSTA, LORI CASTILLO, MEGHAN SCHULZE, NICOLE GREMILLION, LYNDA EHRICH, MARY LOGGER, CITY OF ANTIOCH, TREVOR SCHNITZIUS, KRISTOPHER KINT, OFFICER WHITE, PAULA McEVOY, and Does 1-10, inclusive, Defendants.
ROBERT R. POWELL, ESQ. CSB# 159747, BRETT O. TERRY, ESQ. CSB# 270694, LAW OFFICES OF ROBERT R. POWELL, San Jose, California, Attorneys for Plaintiffs.
JAMES V. FITZGERALD, III, ESQ. CSB# 55632, PETRA BRUGGISSER CSB# 241173, McNAMARA, NEY, BEATTY, SLATTERY, BORGES & AMBACHER LLP, Walnut Creek, CA, Attorneys for Defendants, CITY OF ANTIOCH, TREVOR SCHNITZIUS, KRISTOPHER KINT, and OFFICER WHITE
PETER M. REHON, ESQ. CSB # 1000123, TYLER J. OLSON, ESQ. CSB 220796, REHON & ROBERTS, A Professional Corporation, San Jose, CA, Attorneys for Defendants, LYNDA EHRICH and MARY LOGGER.
SHARON L. ANDERSON, ESQ. CSB # 94814, County Counsel, MONIKA L. COOPER, ESQ. CSB # 193729, Supervising Deputy County Counsel, JANICE AMENTA, ESQ. CSB #161260, Deputy County Counsel, COUNTY OF CONTRA COSTA, Martinez, California, Attorneys for Defendants, COUNTY OF CONTRA COSTA, MEGHAN SCHULZE, NICOLE GREMILLION, AND LORI CASTILLO.
STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
CHARLES R. BREYER, District Judge.
All parties to this action, believing that good cause exists, stipulate and agree, by and through their respective counsel, as follows:
1. The parties have exchanged written discovery and document production requests following the initial case management conference. However, due to several obstacles, especially the Contra Costa County Superior Court's process involving the release of the juvenile dependency court records and the parties' efforts to agree upon and obtain a stipulated protective order before exchanging confidential documents, the parties have not been able to produce any documents in this case until this week.
2. Specifically, obtaining the juvenile dependency court records from the Contra Costa County Superior Court has been a particularly challenging process. Even though a request for the release of the juvenile case file was submitted on January 17th, 2013, the records were not made available by the court until May 28, 2013. The delay was largely due to the number of such requests in the Contra Costa County Superior Court and the fact that a new judge, who was unfamiliar with the process, had been assigned to deal with the requests at the beginning of this year.
3. In addition, due to the confidential nature of the underlying juvenile proceedings and the involvement of a minor plaintiff, the parties wanted to ensure that a protective order was in place before exchanging any confidential documents. The Court signed the parties' stipulated protective order on May 24, 2013. (See Doc. # 59, filed May 24, 2013).
4. Absent the production of any documents, the parties have not taken any depositions in this case to date. However, now that the juvenile case file has been released and the Court has signed the protective order, the parties are in the process of producing documents in this case. Once the documents have been exchanged, the parties will need sufficient time to evaluate the information and will then schedule the depositions of the involved parties. The parties believe that they will be in a position to schedule the depositions within the next 45-60 days, prior to the settlement conference with Hon. Magistrate Judge Maria Elena James.
5. A Settlement Conference has been scheduled with Magistrate Judge Maria-Elena James on July 12, 2013.
6. Based on the foregoing, the parties wish to continue to Case Management Conference, which is currently set for June 14, 2013, for 60 days to allow the parties sufficient time to conduct their discovery and to evaluate the case. The parties believe that good cause exists for such reasonable continuation to save judicial time, resources, fees and costs.
7. Therefore, the parties seek the Court's approval to continue the Case Management Conference, currently set for June 14, 2013, for 60 days to at date and time chosen by the ...