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Stipulation and Order to Elect Referral of Action to VDRP

OFFICE OF THE COUNTY COUNSEL

County of San Joaquin

JASON R. MORRISH, CSB #192686

Deputy County Counsel

Courthouse - Room 711

222 East Weber Avenue

Stockton, California 95202

Telephone: (209) 468-2980

Attorneys for Defendants, 

 COUNTY OF SAN JOAQUIN, DEPUTY RICHARD

 DUNSING, and LT. MENDOZA

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

ROBERT T. BROWN, individually and on

behalf of Class of Persons similarly situated,

 

Plaintiff, 

vs.

COUNTY OF SAN JOAQUIN, SHERIFF

BAXTER DUNN, SHERIFF’S DEPARTMENT

OF SAN JOAQUIN COUNTY and DOES I

through X inclusive,

 

 Defendants.

CASE NO. CIV.S-04-2008 FCD PAN

 

STIPULATION AND ORDER TO

ELECT REFERRAL OF ACTION TO

VOLUNTARY DISPUTE

RESOLUTION PROGRAM (VDRP)

PURSUANT TO LOCAL RULE 16-271

 

Plaintiff ROBERT T. BROWN and Defendants COUNTY OF SAN JOAQUIN,

DEPUTY RICHARD DUNSING, and LT. MENDOZA, by and through their respective counsel,

respectfully submit this STIPULATION AND ORDER TO ELECT REFERRAL OF

ACTION TO VOLUNTARY DISPUTE RESOLUTION PROGRAM (VDRP) PURSUANT

TO LOCAL RULE 16-271 for consideration by the Court. Pursuant to Local Rule 16-271, the

parties hereby agree to submit the above-entitled action to the Voluntary Dispute Resolution

Program [“VDRP”].

As required by Local Rule 16-271(i)(2), the parties submit the following

(A) The parties propose that the VRDP process be completed on or before October 6,

2006, and that the Neutral file confirmation of that completion on or before October 13, 2006.

Case 2:04-cv-02008-FCD-EFB Document 63 Filed 08/22/06 Page 1 of 2
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Stipulation and Order to Elect Referral of Action to VDRP

(B) The parties suggest that the Pre-Trial Conference currently set for September 1,

2006, be vacated. There is no trial date.

(C) There are no pre-trial activities to be completed before the VDRP session is held. 

The parties are hopeful that a resolution may be achieved with the assistance of the Neutral

Respectfully submitted,

OFFICE OF THE COUNTY COUNSEL

Dated: August 18, 2006 By: /s/ Jason R. Morrish 

JASON R. MORRISH 

 Deputy County Counsel

Attorneys for Defendants,

COUNTY OF SAN JOAQUIN, DEPUTY

RICHARD DUNSING and LT. MENDOZA

Dated: August 18, 2006 By: /s/ Bruce W. Nickerson 

BRUCE W. NICKERSON 

 Attorney at Law

Attorney for Plaintiff,

ROBERT T. BROWN

ORDER OF THE COURT

The parties to this action having agreed to submit the above-entitled action to the

Voluntary Dispute Resolution Program [“VDRP”], and good cause appearing therefor,

IT IS HEREBY ORDERED THAT:

The above-entitled action be, and hereby is, referred to VDRP.

The September 1, 2006, date for the Pre-Trial Conference is VACATED and RESET for

Friday, November 17, 2006 at 3:30 p.m. The joint pretrial statement shall be filed no later than

November 9, 2006. 

Dated: August 22, 2006 /s/ Frank C. Damrell Jr. 

Hon. Frank C. Damrell, Jr.

United States District Judge

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