Filed: Nov. 12, 2019
Latest Update: Nov. 12, 2019
Summary: STIPULATION AND ORDER REQUESTING EARLY SETTLEMENT CONFERENCE DATE AND STAY OF DISCOVERY AND RESPONSIVE PLEADINGS JOHN A. MENDEZ , District Judge . The parties have met and conferred and have agreed to participate in an early Settlement Conference with Magistrate Judge Kendall Newman presiding. IT IS HEREBY STIPULATED AND AGREED by and between the parties, through their counsel of record, as follows: 1. That this matter be referred to Magistrate Judge Kendall Newman for a Settlement Confe
Summary: STIPULATION AND ORDER REQUESTING EARLY SETTLEMENT CONFERENCE DATE AND STAY OF DISCOVERY AND RESPONSIVE PLEADINGS JOHN A. MENDEZ , District Judge . The parties have met and conferred and have agreed to participate in an early Settlement Conference with Magistrate Judge Kendall Newman presiding. IT IS HEREBY STIPULATED AND AGREED by and between the parties, through their counsel of record, as follows: 1. That this matter be referred to Magistrate Judge Kendall Newman for a Settlement Confer..
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STIPULATION AND ORDER REQUESTING EARLY SETTLEMENT CONFERENCE DATE AND STAY OF DISCOVERY AND RESPONSIVE PLEADINGS
JOHN A. MENDEZ, District Judge.
The parties have met and conferred and have agreed to participate in an early Settlement Conference with Magistrate Judge Kendall Newman presiding.
IT IS HEREBY STIPULATED AND AGREED by and between the parties, through their counsel of record, as follows:
1. That this matter be referred to Magistrate Judge Kendall Newman for a Settlement Conference, on February 18, 2020, at 9:00 a.m., in Courtroom 25;
2. Except for Rule 26(a) disclosures and the discovery described below, all formal discovery is stayed until 20 days after completion of the Settlement Conference;
3. The parties agree to cooperate in the informal exchange of information needed to prepare for the Settlement Conference, including exchanging the documents enumerated in Section 1 of the Proposed Protective Order;
4. Plaintiff agrees to cooperate with the Defendants noticing and taking up to three preliminary medical depositions,1 including the deposition of two medical providers and a medical expert designated by Plaintiff to prepare for the Settlement Conference;
5. Defendants agree to cooperate with Plaintiff noticing and taking of up to three preliminary percipient witness depositions; provided however, that if any of these witnesses are employees of the defendants, then the deposition will not be considered "preliminary", but as a regular deposition under the discovery rules;
6. The parties agree to meet and confer and submit a Joint Status Report 20 days following the Settlement Conference.
7. Responsive pleadings shall be due 20 days after completion of the Settlement Conference.
IT IS SO STIPULATED.
Dated: 11/11/2019 PORTER SCOTT
A PROFESSIONAL CORPORATION
By: /s/ Carl L. Fessenden
Carl L. Fessenden
Megan E. Nevin
Attorneys for Defendants NEVADA COUNTY,
NEVADA COUNTY SHERIFF'S
DEPARTMENT and SHERIFF KEITH
ROYAL
Dated: 11/11/2019 LAW OFFICE OF PATRICK H. DWYER
By: /s/ Patrick H. Dwyer (authorized 11/08/2019)
Patrick H. Dwyer
Attorney for Plaintiff SONYA CHEYENNE
CAVENDER
Dated: 11/11/2019 LAW OFFICE OF JEROME M. VARANINI
By: /s/ Jerome M. Varanini (authorized 11/08/2019)
Jerome M. Varanini
Attorneys for Defendant WELLPATH
MANAGEMENT, INC. (formerly known as
Correctional Medical Group Companies, Inc.)
and RHONNA TINDALL; and AMANDA
TIRPACK
ORDER
The Court, having reviewed and considered the Parties' Stipulation for an early Settlement Conference and finding good cause therefore, hereby approves:
1. That this matter be referred to Judge Kendall Newman for a Settlement Conference on February 18, 2020, at 9:00 a.m., in Courtroom 25.
2. Discovery shall occur as set forth in the parties' Stipulation;
3. The parties shall complete Joint Status Reports and submit them to the Court within 20 days of the completion of the Settlement Conference;
4. Responsive pleadings shall be due 20 days after completion of the settlement conference.
IT IS SO ORDERED.
