Pickard v. Department of Justice

Filing 187

ORDER granting 186 STIPULATION Requesting Modification of Briefing Schedule filed by William Leonard Pickard. Reset Deadlines as to 184 MOTION for Summary Judgment , Responses due by 1/28/2014. Replies due by 2/18/2014. Motion Hearing set for 4/4/2014 10:00 AM in Courtroom 6, 17th Floor, San Francisco before Hon. Charles R. Breyer. Cross Motions due by 1/28/2014. Response dlue 2/18/2014. Signed by Judge Charles R. Breyer on 1/17/2014. (beS, COURT STAFF) (Filed on 1/17/2014)

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MARK RUMOLD, Esq. (SBN 279060)
1333 Gough St.
San Francisco, CA 94109
[phone]
[e-mail]
Attorney for Plaintiff
William Pickard

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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WILLIAM LEONARD PICKARD,
Plaintiff,

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v.
DEPARTMENT OF JUSTICE,
Defendant.

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Case No.: 3:06-cv-00185-CRB
STIPULATED REQUEST TO MODIFY
BRIEFING SCHEDULE AND ORDER
Date: March 28, 2014
Time: 10:00 a.m.
Place: Ctrm. 6, 17th Floor
Hon. Charles R. Breyer

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Subject to the approval of the Court, the parties hereby stipulate to modify the summary
judgment briefing schedule and hearing date. Good cause exists for this request as follows:

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The Court granted the parties’ stipulation on summary judgment briefing on November 1,

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2013 (ECF No. 183). Defendant filed its fourth motion for summary judgment on January 7, 2014

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(ECF No. 184). Plaintiff’s cross-motion for summary judgment and opposition is currently due

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January 21, 2014. However, the current briefing schedule provides only two weeks to prepare

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plaintiff’s filing. Although plaintiff’s counsel previously believed two weeks would be sufficient to

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prepare the motion, litigation deadlines in other cases shifted over the holidays, and have thus far

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prevented counsel from preparing the motion. Plaintiff thus seeks a one-week continuance for the

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filing of his cross motion and an according one-week adjustment to the case’s remaining deadlines.

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The new schedule, as stipulated by the parties, is as follows:
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STIPULATED REQUEST TO MODIFY BRIEFING SCHEDULE AND
[PROPOSED] ORDER
No. 3:06-cv-00185-CRB

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(1) Plaintiff’s Cross-Motion and Opposition to Defendant’s Summary Judgment is due
January 28, 2014;
(2) Defendant’s Opposition to Plaintiff’s Cross-Motion and Reply in Support of Summary
Judgment is due February 18, 2014;

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(3) Plaintiff’s Reply in Support of Summary Judgment is due March 4, 2013;

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(4) Hearing on cross-motions scheduled for April 4, 2014.

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The parties respectfully request that the schedule above be adopted in place of the schedule

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previously proposed. The page limits remain the same as before.

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Dated: January 17, 2014

Respectfully submitted,
By:

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/s/ Mark Rumold__
MARK RUMOLD
Counsel for Plaintiff

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MELINDA HAAG
United States Attorney

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Dated: January 17, 2014

By:

/s/ Neill T. Tseng___
NEILL T. TSENG
Assistant United States Attorney
Counsel for Defendant

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DECLARATION PURSUANT TO LOCAL RULE 5-1
I, Mark Rumold, attest that I have obtained the concurrence of Neill T. Tseng, Counsel for
Defendant, in the filing of this document.
Executed on January 17, 2014, in San Francisco, California.
/s/ Mark Rumold
Mark Rumold

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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STIPULATED REQUEST TO MODIFY BRIEFING SCHEDULE AND
[PROPOSED] ORDER
No. 3:06-cv-00185-CRB

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IT IS

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HONORABLE CHARLES R. BREYER
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UNITED STATES RDER DISTRICT JUDGE
O O SENIOR
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DATED: January 17, 2014

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STIPULATED REQUEST TO MODIFY BRIEFING SCHEDULE AND
[PROPOSED] ORDER
No. 3:06-cv-00185-CRB

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