Blight v. Manteca et al

Filing 133

STIPULATION and ORDER 132 signed by Senior Judge William B. Shubb on 9/7/2017 continuing 93 Defendants' Motion for Summary Judgment, or in the alternative, Summary Adjudication from 9/18/2017 to 10/16/2017 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. Defendants' deadline to file their reply is 9/18/2017 by Noon (12:00 p.m.). (Kirksey Smith, K)

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DALE L. ALLEN, JR., State Bar No. 145279
[e-mail]
KEVIN P. ALLEN, State Bar No. 252290
[e-mail]
ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP
180 Montgomery Street, Suite 1200
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants
CITY OF MANTECA, ARMANDO GARCIA, IAN
OSBORN, PAUL CARMONA and CHRIS S. MRAZ

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UNITED STATES DISTRICT COURT

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO COURTHOUSE

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JOANNE BLIGHT,
Plaintiff,

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Case No.: 2:15-cv-02513-WBS-AC
STIPULATION RE: SUMMARY JUDGMENT
DEADLINES; [PROPOSED] ORDER

v.
CITY OF MANTECA, a Municipal
Corporation, Manteca Police Department
Detectives ARMANDO GARCIA,
Individually, RANCH JOHNSON,
Individually, KIRK DOTY, Individually,
MIKE KEENER, Individually, IAN
OSBORN, Individually, and ARMEN
AVAKIAN, Individually, Manteca Police
Department Sergeants PAUL CARMONA
and CHRIS S. MRAZ, in their Individual
and Supervisory capacities, and DOES 1
THROUGH 60, Jointly and Severally,

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Defendants.

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TO THE CLERK OF THE COURT, ALL PARTIES, AND THEIR ATTORNEYS
OF RECORD:

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Plaintiff JOANNE BLIGHT (“Plaintiff”) and Defendants CITY OF MANTECA,

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ARMANDO GARCIA, IAN OSBORN, CHRIS MRAZ, and PAUL CARMONA (“Defendants”)

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are hereby respectfully requesting continuance of the existing hearing date (9/18/17) so that

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Defendants have additional time to complete the Reply. The parties request October 16, 2017
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192417.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-AC

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(which they understand is the next available hearing date). Defendants agree to waive Local Rule

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230(d); their Reply would be Monday, September 18, 2017.

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I.

GOOD CAUSE
The record in this matter is voluminous, and Plaintiff’s combined statement of

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facts/opposition brief is lengthy. Despite defense counsel’s best efforts, the Reply cannot be

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completed by the September 11th deadline.1 In view of the length of Plaintiff’s opposition brief

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and separate statement of facts (combined into one document), Plaintiff does not object to

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Defendants’ request.

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Based on the foregoing circumstances, by and through their respective counsel of record,

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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the parties hereby stipulate, and respectfully request that the briefing schedule relating to

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Defendants’ motion for summary judgment/adjudication and, as a result, the hearing date on

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Defendants’ motion, be continued and modified, as follows:

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Judgment/Adjudication be continued from September 18, 2017 to October 16, 2017 at 1:30 p.m.

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That the hearing date for Defendants’ Motion for Summary

2.

Defendants’ deadline to file their Reply is September 18, 2017 by Noon (12:00

p.m.)

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Respectfully submitted,
Dated: September 7, 2017

LAW OFFICES OF SANJAY S. SCHMIDT

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By:

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/s/ Sanjay S. Schmidt
SANJAY S. SCHMIDT
Attorneys for Plaintiff
JOANNE BLIGHT

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If the Court would like the parties to provide additional facts supporting their request, that can
be provided.
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192417.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-AC

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Dated: September 7, 2017

ALLEN, GLAESSNER,
HAZELWOOD & WERTH, LLP

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By:

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PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED.
Dated: September 7, 2017

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180 Montgomery Street, Suite 1200
San Francisco, California 94104

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

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/s/ Kevin P. Allen
DALE L. ALLEN, JR.
KEVIN P. ALLEN
Attorneys for Defendants
CITY OF MANTECA, ARMANDO
GARCIA, IAN OSBORN, PAUL CARMONA
and CHRIS S. MRAZ

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192417.1

STIPULATION; PROPOSED ORDER
2:15-CV-02513-WBS-AC