Landslide Communications et al v. State of California et al

Filing 24

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 8/15/13 ORDERING that the deadline for plaintiff's motion for summary judgment is extended to 8/22/13; opposition and cross-motion due by 9/19/13. (Manzer, C)

BRADLEY W. HERTZ, State Bar No. 138564
1 [e-mail]
JAMES R. SUTTON, State Bar No. 135930
2 [e-mail]
ERIKA M. BOYD, State Bar No. 259633
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THE SUTTON LAW FIRM, LLC.
4 150 Post Street, Suite 405
San Francisco, CA 94108
5 Tel: [phone]
Fax: [phone]
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Attorneys for Plaintiffs
7 LANDSLIDE COMMUNICATIONS, INC.
and JAMES V. LACY, IN HIS CAPACITY
8 AS PRESIDENT OF LANDSLIDE
COMMUNICATIONS, INC.
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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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LANDSLIDE COMMUNICATIONS,
INC. and JAMES V. LACY, IN HIS
CAPACITY AS PRESIDENT OF

Case No.: 2:13-CV-00716-GEB-KJN

LANDSLIDE COMMUNICATIONS, INC.,

STIPULATION FOR EXTENSION OF
FILING DATES FOR PLAINTIFFS’
SUMMARY JUDGMENT MOTION
AND DEFENDANTS’ OPPOSITION
AND CROSS-MOTION FOR
SUMMARY JUDGMENT

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Plaintiffs,

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v.
STATE OF CALIFORNIA; KAMALA
HARRIS, in her capacity as Attorney
General of California; CALIFORNIA
FAIR POLITICAL PRACTICES
COMMISSION; ANN RAVEL, in her
capacity as Chair of the Fair Political
Practices Commission,

[PROPOSED] ORDER
Date: November 4, 2013
Time: 9:00am
Judge: Hon. Garland E. Burrell
Dept.: 10

Defendants.

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STIPULATION FOR EXTENSION OF FILING DATES; [PROPOSED] ORDER

WHEREAS, pursuant to the parties’ Joint Status Report, the Court’s August 7, 2013 Status

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(Pretrial Scheduling) Order set August 15, 2013 as the filing date for Plaintiffs’ Motion for Summary

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Judgment, and September 12, 2013 as the filing date for Defendants’ Opposition and Cross-Motion for

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Summary Judgment. The parties request that the Court grant an extension of time for the filing of

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these papers to August 22, 2013 and September 19, 2013 respectively.

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Due to the unexpected unavailability of Plaintiff James Lacy, Plaintiffs will be unable to file

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their Motion for Summary Judgment by August 15, 2013. Plaintiffs respectfully seek this extension of

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time and will have all moving papers prepared and filed by August 22, 2013. Plaintiffs have not

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previously requested an extension of time regarding this filing.

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In accord with Local Rule 144(a), Plaintiffs’ counsel conferred with Defendants’ counsel, who

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has stipulated to this extension of time. As Plaintiffs seek a week-long extension as to their summary

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judgment filing, the parties agreed to a week-long extension for Defendants’ filing as well. Thus, the

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parties respectfully request that the September 12, 2013 filing date for Defendants’ papers, be

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extended to September 19, 2013.

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This extension of time will not affect the hearing date established by the Court, nor the amount

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of time the Court will have to consider the parties’ filings prior to the hearing. All other filing

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deadlines established in the Court’s August 7, 2013 Order will remain the same. Thus, Plaintiffs’

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Opposition to Defendants’ Cross-Motion and Reply shall be filed October 3, 2013; Defendants’ Reply

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in Support of their Cross-Motion for Summary Judgment shall be filed October 17, 2013; and the

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hearing on the motion shall take place November 4, 2013.

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STIPULATION FOR EXTENSION OF FILING DATES; [PROPOSED] ORDER

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through

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their respective counsel, that the filing date for Plaintiffs’ Motion for Summary Judgment be extended

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from August 15, 2013 to August 22, 2013, and that the filing date for Defendants’ Opposition and

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Cross-Motion for Summary Judgment be extended from September 12, 2013 to September, 19, 2013.

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Dated: August 13, 2013

__/s/ Erika M. Boyd_____________________
Erika M. Boyd
Attorney for Plaintiffs Landslide Communications, Inc.
and James V. Lacy, in his Capacity as President of
Landslide Communications, Inc.

Dated: August 13, 2013

__/s/ Benjamin M. Glickman______________
Benjamin M. Glickman
Attorney for Defendants State of California, Kamala
Harris, in her capacity as Attorney General of California,
California Fair Political Practices Commission, and Ann
Ravel, in her capacity as Chair of the Fair Political
Practices Commission

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ORDER
In light of the parties’ stipulation, the filing of Plaintiffs’ Motion for Summary Judgment

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currently set for August 15, 2013 is extended to August 22, 2013, and that the filing of

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Defendants’ Opposition and Cross-Motion for Summary Judgment currently set for September

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12, 2013 is extended to September, 19, 2013.

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Dated: August 15, 2013

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STIPULATION FOR EXTENSION OF FILING DATES; [PROPOSED] ORDER