On November 08, 2021 a
Stipulation and Order Filed - Appointing Hon. Sherrh A. Ellsworth (Ret.) as Discovery Referee for Deposition of Jeremie Cox.
was filed
involving a dispute between
Doe, John,
and
County Of San Bernanrdino County Of Sheriff'S Department,
County Of San Bernardino,
County Of San Bernardino Human Services Department,
Cox, Jeremie,
Does 1 - 100,
Hope Academy, Inc,
Provenance,
Savantco,
for Other PI/PD/WD Unlimited
in the District Court of San Bernardino County.
Preview
r" W ’. I -
SUPERIOR“‘
COUNTY D
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SA
ANSEpomF‘aixeofggA
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Christopher J. Keane (SBN 194848) 5y
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THE KEANE LAW FIRM, RC.
8605 Santa Monica Blvd. #23851 filo"
Los Angeles, CA 90069
Telephone: (415) 742-5412
Fax: (415) 520-2282
E-mail: ckeane@keanelaw.com
\oooqomgme
Attorney for Plaintiff
IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA
IN AND FOR THE COUNTY OF SAN BERNARDINO
(UNLIMITED JURISDICTION)
JOHN DOE, Case No.2 CIVSB213 1751
Plaintiff,
V.
Hon. Jeffrey Erickson
STIPULATION AND
ORDER APPOINTING HON.
SHERRILL A. ELLSWORTH
W]
COUNTY OF SAN BERNARDINO and (RET.) AS DISCOVERY REFEREE
DOES 2- 1 00, inclusive, jointly and
vvvvvvvvvvvvvvvv
FOR DEPOSITION OF JEREMIE
severally, COX
Defendant(s). Complaint filed: 1 1/8/21
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Trial date: N/A
OOQQUIhDJNb—‘OWWNONUIth—‘O
@fifismcov
Upon stipulation 0f Plaintiff, JOHN DOE, and Defendant, COUNTY OF SAN
BERNARDINO, to the appointment of a discovery referee for the deposition of Jeremie
Cox,
Further, David M. Goldstein, who objected and objects to appointment of a discovery
1
STIPULATION AND [PROPOSED] ORDER APPOINTING DISCOVERY REFEREE FOR
DEPOSITION OF JEREMIE COX
9133213a.m. 04—11—2023 1/1
“9093805525 I
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a
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quugw rm: Uhflstopher Keel
1 referee, but who was given the opportunity by the Conn. acknowledging his objection to
2 a discovery referee, to suggest a discovery referee. Mr. Goldstein requested that any
3 appointed discovery referee being appointed over his objection be a retired judicial
4 officer from IVAMS,
5
6 1T IS HEREBY ORDERED that I-Ion. Sherrill A. Ellsworth (Ret), of IVAMS. is the
_7 appointed discovery referee for the deposition ol‘Jeremie Cox in this action. t0 be taken
8 and completed before June 6, 2023, and it is l’urthcr ordered that said referee shall hear
9 and determine any and all Objections made at the deposition of Jeremie Cox. including
10 but not limited to whether Jeremie Cox is protected or not from answering particular
1 l questions posed to him by the Fifth (S‘h) Amendment.
[2
13 IT IS HEREBY ORDERED that. her stated hourly rate ($550.00) is to be paid by
14 Plaintiff.
15 IT IS SO STIPULATED:
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17
Dated:
41’ l 0/2023 a
18 .
,
.Chlstopher J. Keane
19
20 Dated:
04/ 1o / 2023
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r PlgintilT. John Doc
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21 Chandler A. Parker
Alto -y 1‘ Defendant. County of . n chardino
22
23
Dated: 4/1 Z Ja>
1’
VV David M. Goldstein
24
25
IT IS SO ORDERED:
26
Dated: y/h’L/B
27
28
STII’ULATION AND [PROPOSED] ORDER APPOINTING DISCOVERY REFEREE FOR
DEPOSITION OF JEREMIE COX
Document Filed Date
April 13, 2023
Case Filing Date
November 08, 2021
Category
Other PI/PD/WD Unlimited
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r" W ’. I - SUPERIOR“‘ COUNTY D \r \r ‘ . SA ANSEpomF‘aixeofggA T . Christopher J. Keane (SBN 194848) 5y / ' THE KEANE LAW FIRM, RC. 8605 Santa Monica Blvd. #23851 filo" Los Angeles, CA 90069 Telephone: (415) 742-5412 Fax: (415) 520-2282 E-mail: ckeane@keanelaw.com \oooqomgme Attorney for Plaintiff IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SAN BERNARDINO (UNLIMITED JURISDICTION) JOHN DOE, Case No.2 CIVSB213 1751 Plaintiff, V. Hon. Jeffrey Erickson STIPULATION AND ORDER APPOINTING HON. SHERRILL A. ELLSWORTH W] COUNTY OF SAN BERNARDINO and (RET.) AS DISCOVERY REFEREE DOES 2- 1 00, inclusive, jointly and vvvvvvvvvvvvvvvv FOR DEPOSITION OF JEREMIE severally, COX Defendant(s). Complaint filed: 1 1/8/21 NNNNNNNNNHHr—ni—Iwy—AHHr—Aw Trial date: N/A OOQQUIhDJNb—‘OWWNONUIth—‘O @fifismcov Upon stipulation 0f Plaintiff, JOHN DOE, and Defendant, COUNTY OF SAN BERNARDINO, to the appointment of a discovery referee for the deposition of Jeremie Cox, Further, David M. Goldstein, who objected and objects to appointment of a discovery 1 STIPULATION AND [PROPOSED] ORDER APPOINTING DISCOVERY REFEREE FOR DEPOSITION OF JEREMIE COX 9133213a.m. 04—11—2023 1/1 “9093805525 I v a ‘ .k - ' ”u ‘ . quugw rm: Uhflstopher Keel 1 referee, but who was given the opportunity by the Conn. acknowledging his objection to 2 a discovery referee, to suggest a discovery referee. Mr. Goldstein requested that any 3 appointed discovery referee being appointed over his objection be a retired judicial 4 officer from IVAMS, 5 6 1T IS HEREBY ORDERED that I-Ion. Sherrill A. Ellsworth (Ret), of IVAMS. is the _7 appointed discovery referee for the deposition ol‘Jeremie Cox in this action. t0 be taken 8 and completed before June 6, 2023, and it is l’urthcr ordered that said referee shall hear 9 and determine any and all Objections made at the deposition of Jeremie Cox. including 10 but not limited to whether Jeremie Cox is protected or not from answering particular 1 l questions posed to him by the Fifth (S‘h) Amendment. [2 13 IT IS HEREBY ORDERED that. her stated hourly rate ($550.00) is to be paid by 14 Plaintiff. 15 IT IS SO STIPULATED: w 17 Dated: 41’ l 0/2023 a 18 . , .Chlstopher J. Keane 19 20 Dated: 04/ 1o / 2023 ‘ Atmmcy < l‘ m r PlgintilT. John Doc _,,_V .1 // 21 Chandler A. Parker Alto -y 1‘ Defendant. County of . n chardino 22 23 Dated: 4/1 Z Ja> 1’ VV David M. Goldstein 24 25 IT IS SO ORDERED: 26 Dated: y/h’L/B 27 28 STII’ULATION AND [PROPOSED] ORDER APPOINTING DISCOVERY REFEREE FOR DEPOSITION OF JEREMIE COX