Heizer v. California Department of Developmental Services et al

Filing 21

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 7/14/2014 GRANTING an extension of time up to and including 8/1/2014 for the parties to file a joint status report. (Zignago, K.)

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GEOFFREY M. MACLEAY, Esq.
W. JAMES YOUNG, Esq.
c/o National Right to Work Legal
Defense Foundation, Inc.
8001 Braddock Road, Suite 600
Springfield, Virginia 22160
Telephone:[phone]
Email: [e-mail]
[e-mail]
STEVEN R. BURLINGHAM, Esq.
California Bar No.
Gary, Till & Burlingham
5330 Madison Avenue, Suite F
Sacramento, CA 95841
Telephone: [phone]
Email: [e-mail]
ATTORNEYS FOR PLAINTIFF

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UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO, CALIFORNIA

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DALE HEIZER,

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v.

CASE NO. 2:14-cv-00458-TLN-EFB

Plaintiff,

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INTERNATIONAL UNION OF OPERATING
ENGINEERS, LOCAL 39; AND JOHN
CHIANG, CONTROLLER, STATE OF
CALIFORNIA;

STIPULATED REQUEST FOR
EXTENSION OF TIME TO FILE
JOINT STATUS REPORT;
ORDER

Defendants.

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STIPULATED REQUEST FOR EXTENSION OF TIME
TO FILE JOINT STATUS REPORT
Plaintiff Dale Heizer (hereinafter “Plaintiff”), Defendant John

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Chiang in his official capacity as the State of California

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Controller (hereinafter “Defendant Controller”), and Defendant

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International Union of Operating Engineers, Local 39 (hereinafter

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“Defendant Local 39”), through their undersigned counsel of record,
- 1 STIP. REQUEST FOR EXTENSION TO FILE STATUS REPORT; ORDER

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hereby respectfully request that the parties be granted until and
including August, 1 2014, to file a joint status report.
In support of that request, the parties state as follows:
1. Counsel for Defendant Local 39 only entered the case on June
11, 2014.
2. The parties have conferred and discussed a status report but

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need additional time to finalize it and agree on details.
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3. Counsel for Defendant Controller will be largely unavailable
due to other matters until July 21, 2014.
4. No previous extensions of time to file a joint status report
has been requested or granted in this case.
5. The requested extension of time is necessary because all
parties have only recently made appearances in this case and the
time is needed to prepare a fully agreed-upon report.
6. The requested extension of time will not require the Court

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to reschedule any pretrial dates previously scheduled in this case.

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The foregoing is hereby stipulated between Plaintiff, Defendant

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Controller, and Defendant Local 39, who respectfully request the

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Court to grant the extension of time.

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DATED: 10 July 2014

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GEOFFREY M. MACLEAY, Esq.
W. JAMES YOUNG, Esq.
c/o National Right to Work Legal
Defense Foundation, Inc.
8001 Braddock Road, Suite 600
Springfield, Virginia 22160
Telephone:[phone]
Email: [e-mail]
[e-mail]
- 2 STIP. REQUEST FOR EXTENSION TO FILE STATUS REPORT; ORDER

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STEVEN R. BURLINGHAM, Esq.
California Bar No. 88544
Gary, Till & Burlingham
5330 Madison Avenue, Suite F
Sacramento, CA 95841
Telephone: [phone]
Email: [e-mail]
/s/Geoffrey M. MacLeay
By Geoffrey M. MacLeay
ATTORNEYS FOR PLAINTIFF DALE HEIZER

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KAMALA D. HARRIS
Attorney General of California
MARK R. BECKINGTON
Supervising Deputy Attorney General
KIM L. NGUYEN
Deputy Attorney General
Office of the Attorney General
300 South Spring Street, Suite 1702
Los Angeles, California 90013
Telephone: [phone]
Email: [e-mail]
/s/Kim L. Nguyen
(Approved July 10, 2014)______
By Kim L. Nguyen
ATTORNEYS FOR JOHN CHIANG IN HIS
OFFICIAL CAPACITY AS STATE CONTROLLER
STEWART WEINBERG, Bar No. 031493
ANNE I. YEN, Bar No. 187291
WEINBERG, ROGER & ROSENFELD
A Professional Corporation
1001 Marina Village Parkway, Ste. 200
Alameda, California 94501
Telephone [phone]
E-Mail: [e-mail]
[e-mail]
/s/Stewart Weinberg
(Approved July 10, 2014)
By Stewart Weinberg
ATTORNEYS FOR DEFENDANT INTERNATIONAL
UNION OF OPERATING ENGINEERS,
LOCAL 39
- 3 STIP. REQUEST FOR EXTENSION TO FILE STATUS REPORT; ORDER

ORDER

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Plaintiff Dale Heizer, Defendant State Controller, and
Defendant IUOE, Local 39 have stipulated to an extension of time up
to and including August 1, 2014 for the parties to file a joint
status report.

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IT IS SO ORDERED.
Dated: July 14, 2014

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Troy L. Nunley
United States District Judge

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- 4 STIP. REQUEST FOR EXTENSION TO FILE STATUS REPORT; ORDER