STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 

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Gregory G. Spaulding, Esq. (SB# 106606) 

Terry S. Sterling, Esq. (SB# 106379) 

SPAULDING McCULLOUGH & TANSIL LLP 

90 South E Street, Suite 200 

P.O. Box 1867 

Santa Rosa, CA 95402 

Telephone: (707) 524-1900 / Facsimile: (707) 524-1906 

spaulding@smlaw.com; sterling@smlaw.com 

Attorneys for Defendants 

SONOMA COUNTY SHERIFF'S DEPARTMENT, 

BILL COGBILL and COUNTY OF SONOMA 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

VALERIE GEORGE, as Administrator and 

Personal Representative of THE ESTATE OF 

RYAN GEORGE; VALERIE GEORGE and 

TAJMAH BEAUCHAMP, as Legal 

Representatives for Jaida George and Ryan 

George, Jr.; VALERIE GEORGE, Individually; 

DONALD GEORGE; and TAJMAH 

BEAUCHAMP, Individually, 

 Plaintiffs, 

 vs. 

SONOMA COUNTY SHERIFF'S 

DEPARTMENT; BILL COGBILL; COUNTY 

OF SONOMA; CALIFORNIA FORENSIC 

MEDICAL GROUP, INC.; JAMES LUDERS, 

M.D.; MICHAEL E. DAGEY, R.N.; SUTTER 

HEALTH; SUTTER MEDICAL CENTER OF 

SANTA ROSA; EDWARD W. HARD, M.D.; 

RICHARD FLINDERS, M.D.; JOSEPH N. 

MATEL, M.D.; NORICK JANIAN, M.D.; and 

DOES 1 through 25, inclusive, 

 Defendants. 

Case No.: 3:08-cv-02675-EDL 

STIPULATION AND [PROPOSED] ORDER 

ALLOWING DEFENDANTS COUNTY OF 

SONOMA, SONOMA COUNTY SHERIFF'S 

DEPARTMENT AND BILL COGBILL TO 

FILE MEMORANDA OF POINTS AND 

AUTHORITIES IN EXCESS OF 25 PAGES 

IN LENGTH 

Hon. Elizabeth D. Laporte

Defendants COUNTY OF SONOMA, SONOMA COUNTY SHERIFF'S DEPARTMENT 

and BILL COGBILL intend to file two Motions for Summary Judgment or, in the Alternative, 

Partial Summary Judgment (one Motion will be filed by COUNTY OF SONOMA and SONOMA 

COUNTY SHERIFF'S DEPARTMENT (collectively, "the COUNTY") and a separate Motion will 

Case 3:08-cv-02675-EDL Document 327 Filed 07/26/10 Page 1 of 5
STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 

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be filed by BILL COGBILL). Plaintiffs allege ten causes of action against the COUNTY and 

fourteen causes of action against COGBILL. It is anticipated that the Memorandum of Points and 

Authorities that will be filed in support of each of the two Motions will exceed the 25 pages allowed 

by Local Rules 7-2(b) and 7-4(b). This additional space is necessary to fully argue the complex 

issues presented by the Third Amended Complaint. COUNTY and COGBILL cannot provide the 

Court with a full analysis of the issues subject to summary judgment or partial summary judgment, 

including a complete analysis of the law and facts pertaining thereto, in 25 pages. Defendants 

require additional space, of up to 10 additional pages for each of the two Memoranda that will be 

filed in support of two Motions. Therefore, pursuant to Local Rule 7-12: 

IT IS HEREBY STIPULATED AND AGREED by and among the undersigned counsel that, 

subject to the Court’s approval, the COUNTY and COGBILL may each file a Memorandum of 

Points and Authorities in support of their two separate Motions for Summary Judgment or, in the 

Alternative, Partial Summary Judgment (one Motion to be filed by the COUNTY and one Motion to 

be filed by COGBILL) of up to 35 pages in length. 

DATED: July 23, 2010 SANFORD, WITTELS & HEISLER LLP 

Attorneys for Plaintiffs 

By: /s/ 

 Steven L. Wittels, Esq. 

DATED: July 23, 2010 SPAULDING McCULLOUGH & TANSIL LLP

Attorneys for Defendants 

SONOMA COUNTY SHERIFF'S DEPARTMENT, 

BILL COGBILL and COUNTY OF SONOMA 

By: /s/ 

 Terry S. Sterling, Esq. 

Case 3:08-cv-02675-EDL Document 327 Filed 07/26/10 Page 2 of 5
STIPULATION EXCEEDING PAGE LIMIT AND [PROPOSED] ORDER 3:08-cv-02675-EDL 

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DATED: July 23, 2010 TRIMBLE, SHERINIAN & VARANINI 

Attorneys for Defendants 

CALIFORNIA FORENSIC MEDICAL GROUP, 

INC.; JAMES LUDERS, M.D. and MICHAEL E. 

DAGEY, R.N. 

By: /s/ 

 Jerome M. Varanini, Esq. 

DATED: July 23, 2010 HASSARD BONNINGTON LLP

Attorneys for Defendants 

JOSEPH N. MATEL, M.D. and RICHARD 

FLINDERS, M.D. 

By: /s/ 

 Joanna L. Storey, Esq. 

DATED: July 23, 2010 LAFOLLETTE, JOHNSON, DEHAAS, 

 FESLER & AMES 

Attorneys for Defendant 

SUTTER MEDICAL CENTER OF SANTA ROSA 

By: /s/ 

 Larry Byron Thornton 

DATED: July 23, 2010 ROGASKI, PREOVOLOS, WEBER & 

PATTERSON, LLP 

Attorneys for Defendant 

NORICK JANIAN, M.D. 

By: /s/ 

 Chester A. Rogaski, Jr., Esq. 

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FILER'S ATTESTATION 

Pursuant to General Order 45, section X.B regarding signatures, I hereby attest under penalty 

of perjury that concurrence in the filing of the document has been obtained for any signatures 

indicated by a "conformed" signature (/s/) within this e-filed document. 

DATED: July 23, 2010 SPAULDING McCULLOUGH & TANSIL LLP

Attorneys for Defendants 

SONOMA COUNTY SHERIFF'S DEPARTMENT, 

BILL COGBILL and COUNTY OF SONOMA 

By: /s/ 

 Terry S. Sterling, Esq. 

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[PROPOSED] ORDER

Based on the foregoing Stipulation, and good cause appearing therefore, 

IT IS HEREBY ORDERED: 

Defendants COUNTY OF SONOMA and SONOMA COUNTY SHERIFF'S DEPARTMENT 

(collectively, "the COUNTY"), and BILL COGBILL may each file a Memoranda of Points and 

Authorities in support of their separate Motions for Summary Judgment or, in the Alternative, Partial 

Summary Judgment (one Motion to be filed by the COUNTY and one Motion to be filed by 

COGBILL) of up to 35 pages in length. 

Dated: , 2010__________ 

ELIZABETH D. LAPORTE 

United States Magistrate Judge 

July 26

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Elizabeth D. Laporte

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