Morgan Hill Concerned Parents Association v. California Department of Education

Filing 175

ORDER signed by District Judge Kimberly J. Mueller on 4/13/2016 CONTINUING the hearing on 172 Motion for Judgment on the Pleadings to 7/29/2016 at 10:00 AM in Courtroom 3 (KJM) before District Judge Kimberly J. Mueller. (Michel, G.)

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RONY SAGY (Bar No. 112219)
BARBARA L. GATELY (Bar No. 76497)
SAGY LAW ASSOCIATES
930 Montgomery Street, Suite 600
San Francisco, CA 94133
Telephone: [phone]
Facsimile: 415-956-3950
Email:
[e-mail]
Attorneys for Plaintiffs
MORGAN HILL CONCERNED PARENTS ASSOCIATION and
CONCERNED PARENTS ASSOCIATION

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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MORGAN HILL CONCERNED
PARENTS ASSOCIATION, an
unincorporated association, and
CONCERNED PARENTS
ASSOCIATION, an unincorporated
association,

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STIPULATION AND ORDER RE
CONTINUANCE OF HEARING DATE ON
DEFENDANT’S MOTION FOR JUDGMENT
ON THE PLEADINGS

Plaintiffs,

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CASE NO. 2:11-cv-03471-KJM-AC

v.
CALIFORNIA DEPARTMENT OF
EDUCATION, and DOES 1 through 5,
Defendants.

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WHEREAS Defendant California Department of Education (CDE) noticed a hearing on

22 its Motion for Judgment on the Pleadings for Friday, May 6, 2016 at 10:00 a.m. before The
23 Honorable Kimberly J. Mueller;
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WHEREAS lead counsel for Plaintiffs Morgan Hill Concerned Parents Association and

25 Concerned Parents Association, Rony Sagy, underwent surgery last week—a procedure that
26 requires follow-up visits on Fridays over the next few weeks which prevents her from attending a
27 hearing on Friday, May 6, 2016;
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SAGY LAW
ASSOCIATES

MHCPA & CPA v. CDE / STIPULATION & [PROPOSED] ORDER
CASE #2:11-CV-03471-KJM-AC

WHEREAS lead counsel’s colleague, Barbara L. Gately, will be out of town on May 6,

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2 2016;
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WHEREAS the parties explored other dates which were available on Judge Mueller’s

4 calendar and did not present scheduling conflicts for the parties; and
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WHEREAS the parties have not sought any prior extensions of the hearing date on

6 Defendant’s Motion for Judgment on the pleadings;
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NOW THEREFOR:

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IT IS HEREBY STIPULATED by and between Plaintiffs and Defendant that the

9 hearing on Defendant’s Motion for Judgment on the Pleadings be continued to July 29, 2016 at
10 10:00 a.m. before the Honorable Kimberly J. Mueller.
11 Dated: April 12, 2016

Respectfully submitted,

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By: /S/ Rony Sagy_____________________
RONY SAGY

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Attorneys for Plaintiffs Morgan Hill Concerned
Parents Association and Concerned Parents Assn.

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Dated: April 12, 2016

By:
_____________________________________
JULIA JACKSON
Deputy Attorney General
California Department of Justice

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Attorneys for Defendant California Department of
Education

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GOOD CAUSE APPEARING THEREFOR, IT IS HEREBY ORDERED that the

23 hearing date on Defendant’s Motion for Judgment on the Pleadings be, and hereby is, continued
24 to July 29, 2016 at 10:00 a.m. before this Court.
25 Dated: April 13, 2016
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UNITED STATES DISTRICT JUDGE

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-2SAGY LAW
ASSOCIATES

MHCPA & CPA v. CDE / STIPULATION & ORDER
CASE #2:11-CV-03471-KJM-AC