Pollar et al v. County of Alameda et al

Filing 35

ORDER TO CONTINUE FACT DISCOVERY CUT-OFF DATE re 34 Stipulation filed by Dale Billiter, Mary Takeuchi, County of Alameda, Michael Yee. Signed by Magistrate Judge Bernard Zimmerman on 10/20/2009. (ahy, COURT STAFF) (Filed on 10/20/2009)

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Haapala, Thompson & Abern LLP

Rebecca S. Widen, SBN 219207 Andrea A. Najor, SBN 221853 HAAPALA, THOMPSON & ABERN, LLP 1939 Harrison Street, Suite 800 Oakland, California 94612 Tel: [phone] Fax: [phone] Attorneys For Defendants COUNTY OF ALAMEDA, MARCY TAKEUCHI, DALE BILLITER and MICHAEL YEE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ­ SAN FRANCISCO DANIELLE POLLAR, SHALAWN POLLAR, Guardian Ad Litem for J.A., a minor, ) ) ) ) Plaintiffs, ) ) vs. ) ) COUNTY OF ALAMEDA, MARY ) TAKEUCHI, DALIE BILLITER, MICHAEL ) YEE, CITY OF HAYWARD, SAM ) SANDER, MIKE EDWARDS and DOES 1 ) through 20, inclusive, ) ) Defendants. ) ) Case No.: C08-04196 BZ (JL) STIPULATION AND [PROPOSED] ORDER TO CONTINUE FACT DISCOVERY CUT-OFF DATE

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Attorneys At Law Park Plaza Building 1939 Harrison St., Suite 800 Oakland, California 94612 Telephone: [phone] Facsimile: 510-273-8570

The parties hereto, by and through their undersigned counsel, request that the discovery cut-off in this action be continued for a period of 21 days. The parties have diligently pursued and cooperated in the discovery process. However, due to a combination of witness and counsel unavailability, the parties are unable to complete all fact witness depositions prior to the fact discovery cut-off of November 6, 2009. The parties, therefore, request an additional 21 days within which to complete these depositions and all other fact discovery. No other court-ordered deadlines will be affected if the requested extension is granted. The parties respectfully request that the Court extend the fact discovery cut off in this matter to November 27, 2009. / 1
Pollar v. County of Alameda, et al./Case #C08-04196 BZ Stipulation And [Proposed] Order To Continue Fact Discovery Cut-Off Date

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Haapala, Thompson & Abern LLP

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: October 20, 2009 LAW OFFICES OF ROBERT R. POWELL

By:

*/s/ Robert R. Powell Robert R. Powell Attorneys For Plaintiffs *Mr. Powell provided his verbal consent that this document be electronically filed.

Dated: October 19, 2009

HAAPALA, THOMPSON & ABERN, LLP

By:

/s/ Rebecca S. Widen Rebecca S. Widen Attorneys For Defendants COUNTY OF ALAMEDA, MARCY TAKEUCHI, MICHAEL YEE, and DALE BILLITER

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Pollar v. County of Alameda, et al./Case #C08-04196 BZ Stipulation And [Proposed] Order To Continue Fact Discovery Cut-Off Date

Attorneys At Law Park Plaza Building 1939 Harrison St., Suite 800 Oakland, California 94612 Telephone: [phone] Facsimile: 510-273-8570

Dated: October 20, 2009

CLAPP, MORONEY, BELLAGAMBA, VUCINICH, BEEMAN AND SCHELEY By: */s/ Patrick Co Patrick Co Attorneys For Defendants CITY OF HAYWARD, SAM SANDER and MIKE EDWARDS *Mr. Co provided his consent that this document be electronically filed. ORDER

Pursuant to stipulation and for good cause shown, it is SO ORDERED. Dated: October 20, 2009

Honorable Bernard Zimmerman United States Magistrate Judge