Bhatnagar v. Ingrassia et al

Filing 311

ORDER to extend deadline to meet and confer and to file supplementary declaration re 309 Stipulation filed by County of Contra Costa, City of San Ramon. Signed by Judge Charles R. Breyer on 4/27/09. (be, COURT STAFF) (Filed on 4/27/2009)

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SILVANO B. MARCHESI (SBN 42965) County Counsel GREGORY C. HARVEY(SBN 47974) Assistant County Counsel COUNTY OF CONTRA COSTA 651 Pine Street, 9th Floor Martinez, California 94553 Telephone: [phone] Facsimile: [phone] Electronic mail: [e-mail] Attorneys for Defendants COUNTY OF CONTRA COSTA and CITY OF SAN RAMON Jenny C. Huang Sarita Ordonez Justice First, LLP 2831 Telegraph Avenue Oakland, CA 94609 Telephone: [phone] Facsimile: [phone] Electronic mail: [e-mail] [e-mail] Attorneys for plaintiff ABHINAV BHATNAGAR UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

ABHINAV BHATNAGAR, Plaintiff v. JASON INGRASSIA, et al., Defendants.

No. CV07-02669 CRB STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE FOR TO MEET AND CONFER AND TO FILE SUPPLEMENTARY DECLARATION RE: CONTRA COSTA COUNTY'S MOTION FOR ATTORNEY'S FEES

IT IS HEREBY STIPULATED by and between plaintiff ABHINAV BHATNAGAR and defendants JASON INGRASSIA and CONTRA COSTA COUNTY, by and through their counsel of record, that the deadline to complete the meet-and-confer process and file the supplementary declaration pursuant to this court's order of April 16, 2009 may be extended to
STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE TO MEET AND CONFER AND TO FILE SUPPLEMENTARY DECLARATION RE: CONTRA COSTA COUNTY'S MOTION FOR ATTORNEY'S FEES - CV07-02669 CRB 1

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May 29, 2009 for the reasons stated in the attached Declaration of Gregory C. Harvey. The parties stipulate to the following filing schedule: May 29, 2009 Completion of meet and confer and filing of supplementary declaration regarding fees attributed to the claim of harassing phone calls. June 5, 2009 Filing of Plaintiffs objections to the supplementary declarations of Defendants Ingrassia and the County. June 12, 2009 Filing of Defendants' reply to Plaintiffs objections to the supplementary declarations. SO STIPULATED.

DATED: April 21, 2009

SILVANO B. MARCHESI, County Counsel

By:____________/s/_______________ GREGORY C. HARVEY Assistant County Counsel Attorneys for Defendants COUNTY OF CONTRA COSTA and CITY OF SAN RAMON

STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE TO MEET AND CONFER AND TO FILE SUPPLEMENTARY DECLARATION RE: CONTRA COSTA COUNTY'S MOTION FOR ATTORNEY'S FEES - CV07-02669 CRB 2

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DATED: April 22, 2009

JUSTICE FIRST, LLP

By:_________/s/__________________ JENNY HUANG Attorneys for Plaintiff ABHINAV BHATNAGAR

DATED:

April 22, 2009

MCNAMARA DODGE ET AL., LLP

By:___________/s/_________________
JAMES V. FITZGERALD III Attorneys for Defendant

JASON INGRASSIA

STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE TO MEET AND CONFER AND TO FILE SUPPLEMENTARY DECLARATION RE: CONTRA COSTA COUNTY'S MOTION FOR ATTORNEY'S FEES - CV07-02669 CRB 3

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ORDER IT IS HEREBY ORDERED THAT the deadline for plaintiff and defendants JASON INGRASSIA and CONTRA COSTA COUNTY to complete the meet-and-confer process and for defendants JASON INGRASSIA and CONTRA COSTA COUNTY to file their supplementary declarations pursuant to this court's order of April 16, 2009 is hereby extended to and including May 29, 2009. The court adopts the filing schedule proposed by the parties. SO ORDERED.

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STIPULATION AND (PROPOSED) ORDER TO EXTEND DEADLINE TO MEET AND CONFER AND TO FILE SUPPLEMENTARY DECLARATION RE: CONTRA COSTA COUNTY'S MOTION FOR ATTORNEY'S FEES - CV07-02669 CRB 4

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S DISTRICT TE C TA __________________________________ CHARLES R. BREYER UNITED STATES DISTRICT JUDGE ERED O ORD IT IS S

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