Filed: Jun. 03, 2014
Latest Update: Jun. 03, 2014
Summary: DEFENDANTS' APPLICATION FOR AN ORDER GRANTING PERMISSION TO EXCEED THE TWENTY PAGE LIMIT FOR MOTION FOR SUMMARY JUDGMENT MORRISON C. ENGLAND, Jr., Chief District Judge. Defendants County of Sacramento, John McGinness, Ann Marie Boylan, Michael Sotak, M.D., Susan Kroner RN, Agnes R. Felicano NP, Glayol Sahba, M.D., Deputy John Wilson, Richard Bauer, M.D., Deputy Stephanie Jacoby, Deputy Mark Medeiros, Deputy Mark Iwasa hereby apply for an order granting permission to exceed the twenty page limi
Summary: DEFENDANTS' APPLICATION FOR AN ORDER GRANTING PERMISSION TO EXCEED THE TWENTY PAGE LIMIT FOR MOTION FOR SUMMARY JUDGMENT MORRISON C. ENGLAND, Jr., Chief District Judge. Defendants County of Sacramento, John McGinness, Ann Marie Boylan, Michael Sotak, M.D., Susan Kroner RN, Agnes R. Felicano NP, Glayol Sahba, M.D., Deputy John Wilson, Richard Bauer, M.D., Deputy Stephanie Jacoby, Deputy Mark Medeiros, Deputy Mark Iwasa hereby apply for an order granting permission to exceed the twenty page limit..
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DEFENDANTS' APPLICATION FOR AN ORDER GRANTING PERMISSION TO EXCEED THE TWENTY PAGE LIMIT FOR MOTION FOR SUMMARY JUDGMENT
MORRISON C. ENGLAND, Jr., Chief District Judge.
Defendants County of Sacramento, John McGinness, Ann Marie Boylan, Michael Sotak, M.D., Susan Kroner RN, Agnes R. Felicano NP, Glayol Sahba, M.D., Deputy John Wilson, Richard Bauer, M.D., Deputy Stephanie Jacoby, Deputy Mark Medeiros, Deputy Mark Iwasa hereby apply for an order granting permission to exceed the twenty page limit for their Motion for Summary Judgment set forth in the Court's Pretrial Scheduling Order. Defendants require more than the allowed number of pages in order to properly and adequately address and support the Motion for Summary Judgment.
Plaintiff has brought this action against the County of Sacramento and eleven remaining individual Defendants, including supervisors and members of the Sacramento Sheriff's Department and Main Jail medical staff. Plaintiff brings this action under various theories, including the Eighth and Fourteenth Amendment to the United States Constitution, the Americans with Disabilities Act, Rehabilitation Act and state law claims. In addition, Plaintiff's remaining claims surround two separate incarcerations spanning several months that were originally brought as separate actions.
In order to address the various issues and theories, the defendants must present evidence and argue regarding several liability theories pertaining to:
1. Policies, practices and procedures within the Main Jail;
2. The encounters between the Plaintiff and the individual Defendants and other Main Jail employees during the 2007 incarceration (February 2007 through May 20, 2007);
3. The encounters between the Plaintiff and the individual Defendants and other Main Jail employees during the 2010 incarceration (March 23, 2010 through May 10, 2010).
Because of the federal and state law claims alleged against multiple individual Defendants and the County spanning two separate incarcerations, Defendants respectfully request permission to file a Memorandum of Points and Authorities not to exceed forty (40) pages in support of their Motion for Summary Judgment.
ORDER
In accordance with the foregoing application, and good cause appearing, the supporting points and authorities for Defendants' Motion for Summary Judgment may be up to 40 pages in length. Plaintiff's opposition is subject to the same 40 page limitation. Defendants' reply, should they choose to file one, may not exceed 20 pages.
IT IS SO ORDERED.
