A.C. et al v. City of Fairfield et al

Filing 11

STIPULATION and ORDER signed by District Judge John A. Mendez on 6/8/16 ORDERING that the deadline to submit a joint status report now set for June 10, 2016 is continued by 30 days to July 8, 2016. (Becknal, R)

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Gregory M. Fox, State Bar No. 070876
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Attorneys for Defendants
City of Fairfield and Officers Joe Griego,
Daniel Hatzell, and Clinton Morgan

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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A.C., individually and as co-successor-ininterest to Decedent JOSE CEJA, by and
through his Guardian-Ad-Litem ALICIA
VILLA; I.C., individually and as co-successorin-interest to Decedent JOSE CEJA, by and
through her Guardian-Ad-Litem ALICIA
VILLA; GUADALUPE VILLA-VARGAS,
individually; ARTURO CEJA-GONZALEZ,
individually; PABLO CEJA, individually and
as Guardian-Ad-Litem for W.C. and J.C.; and
LETICIA CEJA, individually,

Case No. 2:16-cv-00746 JAM-CKD

STIPULATION AND ORDER TO EXTEND TIME
TO SUBMIT JOINT STATUS REPORT

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Plaintiff,
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v.
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CITY OF FAIRFIELD, a municipal
corporation; JOE GRIEGO, individually and in
his official capacity as a police officer for the
City of Fairfield; DANIEL HATZELL,
individually and in his official capacity as a
police officer for the City of Fairfield;
CLINTON MORGAN, individually and in his
official capacity as a police officer for the City
of Fairfield; and DOES 1-25, inclusive,
individually, jointly and severally,
Hon. John A. Mendez

Defendants.

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Plaintiffs A.C., by and through his Guardian-Ad-Litem ALICIA VILLA, I.C., by and through her

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Guardian-Ad-Litem

ALICIA

VILLA,

GUADALUPE

VILLA-VARGAS,

ARTURO

CEJA-

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GONZALEZ, PABLO CEJA, W.C., by and through his Guardian-Ad-Litem PABLO CEJA, J.C., by and
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT JOINT STATUS REPORT
A.C., et al. v. City of Fairfield, et al. USDC Eastern Dist. Case No. 2:16-cv-00746-JAM-CKD

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through her Guardian-Ad-Litem PABLO CEJA and LETICIA CEJA (hereinafter “Plaintiffs”) and

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Defendants CITY OF FAIRFIELD, JOE GRIEGO, DANIEL HATZELL, and CLINTON MORGAN

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(hereinafter “Defendants”), by and through their counsel of record, hereby represent to the Court as

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follows:

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On April 11, 2016, Plaintiffs filed their Complaint in the above captioned action. Defendants

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were served on April 13, 2016. Therefore, pursuant to the standing Order Requiring Joint Status Report,

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the parties' report is due June 10, 2016.

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The schedules of counsel have limited the ability of the parties to meet and confer regarding

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preparation of the joint status report. A 30-day extension of time to prepare and submit the joint status

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report will allow the parties adequate time to prepare a full and complete joint status report, including a

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discovery schedule and plan.

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Therefore, the parties request that the deadline to submit a joint status report now set for June 10,
2016 be continued by 30 days to July 8, 2016.

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Dated: June 8, 2016

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BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
By: /s/ Gregory M. Fox
Gregory M. Fox
Attorneys for Defendants
City of Fairfield and Officers Joe Griego, Daniel
Hatzell, and Clinton Morgan

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Dated: June 8, 2016

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LAW OFFICES OF JOHN L. BURRIS
By: /s/Melissa C. Nold______________________
Melissa C. Nold
Attorneys for Plaintiffs

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ELECTRONIC CASE FILING ATTESTATION

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I, Gregory M. Fox, am the ECF user whose identification and password are being used to file the

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foregoing documents. Pursuant to Civil Local Rule 131(e), I hereby attest that concurrence in the filing

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of these documents has been obtained from each of its Signatories.

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Dated: June 8, 2016

/s/ Gregory M. Fox
Gregory M. Fox
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT JOINT STATUS REPORT
A.C., et al. v. City of Fairfield, et al. USDC Eastern Dist. Case No. 2:16-cv-00746-JAM-CKD

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: 6/8/2016

/s/ John A. Mendez_______________________
John A. Mendez
UNITED STATES DISTRICT COURT JUDGE

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO SUBMIT JOINT STATUS REPORT
A.C., et al. v. City of Fairfield, et al. USDC Eastern Dist. Case No. 2:16-cv-00746-JAM-CKD