Padilla v. Beard et al

Filing 55

STIPULATION AND ORDER signed by Magistrate Judge Carolyn K. Delaney on 9/15/2015 GRANTING the stipulated request for a 7-day continuance of the motion hearing on 51 Motion for Protective Order; CONTINUING the motion hearing on 51 Motion for Protective Order to 10/7/2015 at 10:00 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney. (Michel, G.)

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
CHRISTOPHER J. BECKER, State Bar No. 230529
Supervising Deputy Attorney General
DIANA ESQUIVEL, State Bar No. 202954
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Defendants Acevedo, Baer, Beard,
Castro, Davey, Drew, Garcia, Gipson, Godina,
Holguin, Johnson, Kaiser, LaClaire, Martinez,
Overley, Pruneda, Robicheaux, Silva, Sao, Solis,
Stainer, and Wagner

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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JERMAINE PADILLA,

No. 2:14-cv-01118 KJM-CKD

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v.
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JEFFREY BEARD, et al.,

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Plaintiff, STIPULATION AND PROPOSED
ORDER FOR ONE-WEEK
CONTINUANCE OF HEARING ON
DEFENDANT BEARD’S MOTION FOR
PROTECTIVE ORDER
[L.R. 230(f)]
Defendants.

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Under Local Rules 230(f) and 143, Plaintiff and Defendants, by and through their

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respective counsel of record, stipulate to a one-week continuance of the hearing on Defendant

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Beard’s motion for protective order, currently scheduled to be heard on September 30, 2015 at 10

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a.m. in Courtroom 24.

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Good cause exists to grant this stipulated request because counsel for the parties will be in a

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deposition in connection with this case on September 30. Depending on the number of matters on

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the Court’s calendar for September 30, the hearing may delay the deposition for a lengthy period
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Stipulation and Proposed Order for One-Week Continuance of Hearing on Defendant Beard’s Motion for Protective
Order (2:14-cv-1118 KJM-CKD)

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of time. Further, Plaintiff’s counsel wishes to be present at the hearing on Beard’s motion, but

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will be unable to do so because of the pending deposition. Good cause further exists because the

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parties have agreed to avail themselves of the Court’s informal telephonic conference procedure

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provided by Magistrate Judge Delaney. A short continuance of the hearing will allow the parties

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to participate in this informal process, and potentially avoid having to pursue, and burden the

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Court with, a formal discovery motion.

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IT IS SO STIPULATED.

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Dated: September 10, 2015

Respectfully submitted,

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KAMALA D. HARRIS
Attorney General of California
CHRISTOPHER J. BECKER
Supervising Deputy Attorney General

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/s/ Diana Esquivel

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DIANA ESQUIVEL
Deputy Attorney General
Attorneys for Defendants

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Dated: September 10, 2015

RIFKIN LAW OFFICE

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/s/ Lori Rifkin

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Lori Rifkin
Attorneys for Plaintiff

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SA2014313303
32208407.doc

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Stipulation and Proposed Order for One-Week Continuance of Hearing on Defendant Beard’s Motion for Protective
Order (2:14-cv-1118 KJM-CKD)

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ORDER
Good cause appearing, the parties’ stipulated request for a seven-day continuance of the
hearing on Defendant Beard’s motion for protective order is granted.
The hearing scheduled in this matter for September 30, 2015 at 10 a.m. is continued to
October 7, 2015 at 10 a.m. in Courtroom 24 before the undersigned.

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IT IS SO ORDERED.

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Dated: September 15, 2015

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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Stipulation and Proposed Order for One-Week Continuance of Hearing on Defendant Beard’s Motion for Protective
Order (2:14-cv-1118 KJM-CKD)