A. v. Folsom Cordova Unified School District

Filing 22

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 2/9/2015 ORDERING 21 that the deadlines set by the Court is EXTENDED; any Motion to supplement the record due by 6/19/2015; Dispositive Motions filed by 9/25/2015, Opposition to motion due by 10/9/2015, reply to opposition due by 10/16/2015; and motion hearing set for 10/30/2015. (Reader, L)

1 FAGEN FRIEDMAN & FULFROST, LLP
Kimberly A. Smith, SBN 176659
2 Anne M. Sherlock, SBN 210205
Cynthia M. Smith, SBN 220861
3 520 Capitol Mall, Suite 400
Sacramento, California 95814
4 Phone: [phone]
Fax: [phone]
5
Attorneys for Defendant, FOLSOM CORDOVA
6 UNIFIED SCHOOL DISTRICT
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

520 Capitol Mall, Suite 400
Sacramento, California 95814
Main: 916-443-0000 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

10
11 KARIM ABDELLA and PATRICIA D.
MORGAN ABDELLA,
12
Plaintiff,
13
vs.
14
FOLSOM CORDOVA UNIFIED SCHOOL
15 DISTRICT,
16

No. 2:14-cv-1259 KJM DAD PS
STIPULATION AND ORDER TO
CONTINUE MOTIONS DEADLINES
AND HEARING DATE

Defendant.

17
18
19
20
21
22
23
24
25
26
27
28
2:14-cv-1259 KJM DAD PS
STIPULATION TO CONTINUE MOTIONS DEADLINES
AND HEARING DATE; [PROPOSED] ORDER

1

WHEREAS, the parties participated in a Status Conference with the Court on October 10,

2 2014;
3

WHEREAS, the Court set deadlines by which the Administrative Record must be lodged

4 with the Court, by which any motion to supplement the record or conduct discovery must be filed,
5 the briefing schedule, and the hearing date;
6

WHEREAS, the parties stipulated twice to extend the date by which the Administrative

7 Record must be lodged with the Court and stipulated once to extend the date by which any motion
8 to supplement the record or conduct discovery must be filed;
9

WHEREAS, the parties lodged the Administrative Record with the Court on January 30,

11
520 Capitol Mall, Suite 400
Sacramento, California 95814
Main: 916-443-0000 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

10 2015;
WHEREAS, it took the parties longer than anticipated to review and lodge the voluminous

12 Administrative Record, and
13

WHEREAS, Plaintiffs have two special education hearings scheduled before the Office of

14 Administrative Hearings in March and April 2015 for their other child, and Plaintiffs require
15 additional time to prepare motions to supplement the record and their motion for summary
16 judgment;
17

WHEREAS, Defendant does not object to extending the deadlines in this matter;

18

WHEREAS, the parties have met and conferred regarding seeking an extension of the

19 briefing schedule and hearing dates set by the Court at the Status Conference on October 10, 2014,
20 and the motion date subsequently extended via stipulation to file motions to supplement the record
21 and/or conduct discovery;
22

WHEREAS, the parties respectfully request that the motion deadline, the briefing

23 schedule, and the hearing date set by the Court be extended in accordance with the parties’
24 stipulation below or to a similar date convenient for the Court’s calendar;
25 / / /
26 / / /
27 / / /
28 / / /
2:14-cv-1259 KJM DAD PS
2
STIPULATION TO CONTINUE MOTIONS DEADLINES
AND HEARING DATE; [PROPOSED] ORDER

1

IT IS STIPULATED THAT the following deadlines will take effect:

2

File any Motion to Supplement the Record

June 19, 2015

3

File any Motion for Summary Judgment

September 25, 2015

4

Opposition to Motion for Summary Judgment

October 9, 2015

5

Reply to Opposition to Motion for Summary Judgment

October 16, 2015

6

Motion Hearing

October 30, 2015

7
8

DATED: February 4 , 2015

/s/ Patricia D. Morgan
Patricia D. Morgan Abdella, In Pro Se

DATED: February 4 , 2015

/s/ Karim A. Abdella
Karim A. Abdella, In Pro Se

DATED: February 4 , 2015

FAGEN FRIEDMAN & FULFROST, LLP

9

11
520 Capitol Mall, Suite 400
Sacramento, California 95814
Main: 916-443-0000 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

10

12
13
14
15
16

By:

/s/ Cynthia M. Smith
Cynthia M. Smith
Attorneys for Defendant, FOLSOM
CORDOVA UNIFIED SCHOOL DISTRICT

17
18
19
20
21
22
23
24
25
26
27
28
2:14-cv-1259 KJM DAD PS
3
STIPULATION TO CONTINUE MOTIONS DEADLINES
AND HEARING DATE; [PROPOSED] ORDER

1

ORDER

2

Pursuant to the stipulation of the parties to this matter, IT IS ORDERED THAT the

3 deadlines set by the Court be extended as follows:
4

File any Motion to Supplement the Record

June 19, 2015

5

File any Motion for Summary Judgment

September 25, 2015

6

Opposition to Motion for Summary Judgment

October 9, 2015

7

Reply to Opposition to Motion for Summary Judgment

October 16, 2015

8

Motion Hearing

October 30, 2015

9 Dated: February 9, 2015

11
520 Capitol Mall, Suite 400
Sacramento, California 95814
Main: 916-443-0000 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

10

12
13
14
Ddad1\orders.pro se

15 abdella1259.stip.eot2.ord.docx
16
17
18
19
20
21
22
23
24
25
26
27
28
2:14-cv-1259 KJM DAD PS
4
STIPULATION TO CONTINUE MOTIONS DEADLINES
AND HEARING DATE; [PROPOSED] ORDER