V.W. v. City of Vallejo, et al.,

Filing 8

STIPULATION and ORDER signed by Judge Lawrence K. Karlton on 8/31/2012 re: 7 Stipulation and Proposed Order; Status Conference CONTINUED to 10/9/2012 at 03:00 PM in Courtroom 4 (LKK) before Judge Lawrence K. Karlton. (Waggoner, D)

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CLAUDIA M. QUINTANA, SBN 178613
City Attorney
By: Alan M. Cohen, SBN 177662
Deputy City Attorney
CITY OF VALLEJO
555 Santa Clara Street, Third Floor
Vallejo, CA 94590
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants City of Vallejo and
Robert Nichelini
JOHN L. BURRIS, Esq./ State Bar #69888
BENJAMIN NISENBAUM, Esq./ State Bar #222173
LAW OFFICES OF JOHN L. BURRIS
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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V.W, a minor, by and through her Guardian Ad
Litem, Tenaya Barber, Individually and as
Successor in Interest of Decedent MICHAEL
WHITE,

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Case No: 2:12-cv-01629-LKK-GGH
STIPULATION AND ORDER
CONTINUING SEPTEMBER 10, 2012
STATUS CONFERENCE

Plaintiffs
(Complaint Filed: June 18, 2012)

v.

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CITY OF VALLEJO, a municipal corporation;
ROBERT NICHELINI, in his individual and
official capacity as Chief of Police; Officers Does
1-25, individually, jointly and severally

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Defendants

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V.W. v. City of Vallejo, et al.
Case No: 2:12-cv-01629-LKK-GGH

STIPULATION AND [PROPOSED] ORDER
CONTINUING SEPTEMBER 10, 2012 STATUS
CONFERENCE

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I.

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STIPULATION
1. The parties in the above-entitled action hereby request a continuance of the Status

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Conference currently set for September 10, 2012 to accommodate Plaintiff’s Counsel Benjamin

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Nisenbaum’s trial schedule and to provide the parties with sufficient time to meet and confer and

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prepare a case management plan.

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2. The parties were unable to meet and confer on a case management plan subsequent to

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Defendants filing their Answer to the Complaint on August 7, 2012 because Plaintiff’s counsel, Mr.

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Nisenbaum was out of the country on his honeymoon and did not return until Tuesday, August 28,

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2012. Mr. Nisenbaum is now scheduled to commence a one month long jury trial beginning on

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September 4, 2012 which will likely conflict with the currently scheduled Status Conference date of

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September 10, 2012.

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3. Based on the foregoing, the parties believe that good cause exists to continue the September

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10, 2012 Status Conference to October 9, 2012 at 3:00 p.m. or as soon thereafter as the matter be

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heard.

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DATED: August 29, 2012

Respectfully submitted,

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/s/ Alan M. Cohen__________
Alan M. Cohen
Deputy City Attorney
Attorney for Defendants
City of Vallejo and Robert Nichelini

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DATED: August 29, 2012

Respectfully submitted,

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/s/ Benjamin Nisenbaum_____
Benjamin Nisenbaum
Law Offices of John Burris
Attorneys for Plaintiff

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V.W. v. City of Vallejo, et al.
Case No: 2:12-cv-01629-LKK-GGH

STIPULATION AND [PROPOSED] ORDER
CONTINUING SEPTEMBER 10, 2012 STATUS
CONFERENCE

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II.

ORDER
FOR THE REASONS stated in the parties Stipulation, the Court hereby grants the parties'

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Stipulation and orders that Status Conference currently set for September 10, 2012 is hereby continued

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to October 9, 2012 at 3:00 p.m.

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IT IS SO ORDERED

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DATED: August 31, 2012.

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V.W. v. City of Vallejo, et al.
Case No: 2:12-cv-01629-LKK-GGH

STIPULATION AND [PROPOSED] ORDER
CONTINUING SEPTEMBER 10, 2012 STATUS
CONFERENCE

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