Filed: Jun. 16, 2015
Latest Update: Jun. 16, 2015
Summary: JOINT STIPULATION AND FOR EXTENSION OF TIME FOR THE FILING OF TRIAL DOCUMENTS; ORDER THEREON MORRISON C. ENGLAND, Jr. , Chief District Judge . Plaintiff, Sandipkumar Tandel, is represented by Geri Green of the Law Offices of Green & Green LLP, and Dennise S. Henderson of the Law Office of Dennise S. Henderson. Defendants, Attorneys for Defendants County of Sacramento, John McGinness, Deputy Stephanie Jacoby and Deputy Mark Medeiros are represented by Van Longyear and Peter C. Zilaff of Long
Summary: JOINT STIPULATION AND FOR EXTENSION OF TIME FOR THE FILING OF TRIAL DOCUMENTS; ORDER THEREON MORRISON C. ENGLAND, Jr. , Chief District Judge . Plaintiff, Sandipkumar Tandel, is represented by Geri Green of the Law Offices of Green & Green LLP, and Dennise S. Henderson of the Law Office of Dennise S. Henderson. Defendants, Attorneys for Defendants County of Sacramento, John McGinness, Deputy Stephanie Jacoby and Deputy Mark Medeiros are represented by Van Longyear and Peter C. Zilaff of Longy..
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JOINT STIPULATION AND FOR EXTENSION OF TIME FOR THE FILING OF TRIAL DOCUMENTS; ORDER THEREON
MORRISON C. ENGLAND, Jr., Chief District Judge.
Plaintiff, Sandipkumar Tandel, is represented by Geri Green of the Law Offices of Green & Green LLP, and Dennise S. Henderson of the Law Office of Dennise S. Henderson. Defendants, Attorneys for Defendants County of Sacramento, John McGinness, Deputy Stephanie Jacoby and Deputy Mark Medeiros are represented by Van Longyear and Peter C. Zilaff of Longyear, O'Dea & Lavra, LLP.
The parties are mindful of the extensive length of trial and the Court's impacted criminal trial calendar. The parties met and conferred and requested in a pending stipulation that the trial and pre-trial dates be continued to February 2016 in the interest of judicial economy. (Dkt. 168) While that stipulation remains under submission, on June 4, 2015, on its own motion vacated the August 31, 2015, jury trial date and continued it to September 8, 2015, and vacated and continued the July 9, 2015, Final Pretrial Conference date to July 30, 2015. (Dkt.169.) The Court left all other due dates set forth in the Court's November 12, 2014 Order Continuing Trial. (Dkt.164.)
The parties now, jointly, request that the due dates for the trial documents be extended for 21 days to correspond to the new date for the Final Pretrial Conference. This request is made on the basis that the parties are engaging and meaningful discussions and collaborations concerning numerous stipulations that would decrease the length of time required to try this case. The stipulations require more time and collaboration between the parties.
Ms. Green has just returned to her office after being away for three weeks. Her father and former law partner is gravely ill and declining rapidly requiring her attention. She is also ill making collaboration difficult at this time. While she is expected to recover, her father, likely, will not. Consequently, the parties request that the filing dates for the trial documents track the new Final Pretrial Conference date and be extended for 21 days as follows:
Documents Present Date Due Requested Date
Joint Final Pretrial Statement
Procedural and Evidentiary Motions June 18, 2015 July 9, 2015
Trial Briefs and Oppositions June 25, 2015 July 16, 2015
Replies July 2, 2015 July 23, 2015
This request is made on the assumption that the Court's calendar will not be adversely affected by the requested continuance in light of the Court's continuance of the Final Pretrial Conference and trial dates.
IT IS SO STIPULATED.
IT IS SO ORDERED.
