Cuviello et al v. City Of Oakland et al

Filing 496

STIPULATION AND ORDER - motion reset from 10/5/12 to 10/26/12 at 1:30 p.m. opp due 9/25/12. Reply due 10/2/12.. Signed by Judge Edward M. Chen on 9/11/12. (bpf, COURT STAFF) (Filed on 9/11/2012)

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G. WHITNEY LEIGH (SBN 153457)
GONZALEZ & LEIGH LLP
744 Montgomery Street, Fifth Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415-912-5951
Attorneys for Plaintiff
DENIZ BOLBOL
JOSEPH P. CUVIELLO
P.O. Box 2834
Redwood City, CA 94064
Telephone: [phone]
[e-mail]
Plaintiff In Pro Se

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION
JOSEPH P. CUVIELLO AND DENIZ
BOLBOL, INDIVIDUALLY,
Plaintiffs,

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Case No. 06-CV-05517-EMC
Related Case No. 09-CV-02955-EMC
CORRECTED STIPULATION AND
[PROPOSED] ORDER CONTINUING
HEARING AND BRIEFING ON
INTERVENOR FELD
ENTERTAINMENT’S MOTION TO
MODIFY THE PRELIMINARY
INJUNCTION, FILED ON AUGUST 28,
2012
(as modified)

v.
CITY OF OAKLAND, A PUBLIC
ENTITY, ALAMEDA COUNTY, A
PUBLIC ENTITY, OAKLANDALAMEDA COLISEUM AUTHORITY, A
PUBLIC ENITITY, OAKLAND
COLISEUM JOINT VENTURE, L.L.C.,
SMG, OAKLAND POLICE OFFICER R.
VALLADON (7184 P), OAKLAND
POLICE OFFICER R. VILLEGAS,
OAKLAND COLLISEUM ASSISTANT
SECURITY MANAGER “SKEET” ELLIS,
AND DOES 1-100, IN THEIR
INDIVIDUAL AND OFFICIAL
CAPACITIES JOINTLY AND
SEVERALLY,
Defendants.

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CORRECTED STIPULATION TO CONTINUE HEARING AND BRIEFING ON FELD
ENTERTAINMENT’S MOTION TO MODIFY THE PRELIMINARY INJUNCTION
Case No. 06-CV-05517-EMC

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The hearing on Intervenor Feld Entertainment, Inc.’s (“Feld Entertainment”) Motion to

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Modify the Permanent Injunction, filed on August 28, 2012, is presently set for October 5, 2012.

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The briefing schedule currently mandates that Plaintiffs Joseph Cuviello and Deniz Bolbol

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(“Plaintiffs”) submit their opposition to Feld Entertainment’s motion by September 11, 2012, and

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for Defendant to submit their reply by September 18, 2012.

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In light of recent circumstances, Plaintiffs have requested, and Feld Entertainment does

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not oppose, that the above dates be extended by two weeks. This would continue the hearing on

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Feld Entertainment’s Motion to Modify the Permanent Injunction to October 19, 2012. The new

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deadline for Plaintiffs’ opposition brief would be September 25, 2012, and the new deadline for

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Feld Entertainment’s reply brief would be October 2, 2012.
Plaintiffs requested this continuance because they have been occupied in Santa Clara

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County Superior Court in trial in the restraining order proceedings referenced in the request for

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judicial notice in support of intervenor Feld’s motion to modify the injunction in this case. As a

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result, Plaintiffs are unable to meet the deadlines currently prescribed by the briefing schedule.

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Pursuant to Local Rule 6-1, Plaintiffs and Feld Entertainment, by and through their

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respective counsel, hereby stipulate and agree that the briefing schedule and hearing date be

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modified as stated above.

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Dated: September 10, 2012

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Respectfully submitted,
GONZALEZ & LEIGH LLP

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By:__/s/ G. Whitney Leigh _________________
G. Whitney Leigh
Attorneys for Plaintiff
DENIZ BOLBOL

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Dated: September 10, 2012

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By:__/s/ Joseph Cuviello_ _________________
JOSEPH CUVIELLO
IN PRO SE

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CORRECTED STIPULATION TO CONTINUE HEARING AND BRIEFING ON FELD
ENTERTAINMENT’S MOTION TO MODIFY THE PRELIMINARY INJUNCTION
Case No. 06-CV-05517-EMC

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Dated: September 10, 2012

McMANIS FAULKNER

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By _/s/ Ruby H. Kazi______________________
Ruby H. Kazi
Attorney for Intervenor
FELD ENTERTAINMENT, INC.

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ORDER

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Good cause appearing, the current dates for Plaintiffs’ opposition brief to Feld
Entertainment’s Motion to Modify the Permanent Injunction, Feld Entertainment’s reply thereto,

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and the current date set for the hearing on said motion, are continued as follows: Plaintiff’s

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opposition brief shall be filed no later than September 25, 2012; Feld Entertainment’s reply brief

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shall be filed no later than October 2, 2012; and the hearing on Feld Entertainment’s Motion to

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Modify the Permanent Injunction shall be held at 1:30 p.m. on October 19, 2012.
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IT IS SO ORDERED.

_________________________________
EDWARD M. CHEN
DERED
United States District Court Judge
SO OR
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9/11/12
Dated: _________________________

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CORRECTED STIPULATION TO CONTINUE HEARING AND BRIEFING ON FELD
ENTERTAINMENT’S MOTION TO MODIFY THE PRELIMINARY INJUNCTION
Case No. 06-CV-05517-EMC

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