Furnace v. Knuckles et al

Filing 270

STIPULATION AND ORDER Enlarging Time to File Stipulation/Proposed Order Resolving Plaintiff's Pending Motion to Compel Compliance with Subpoena to California Department of Corrections and Rehabilitation signed by Magistrate Judge Elizabeth D. Laporte: granting 269 Stipulation. (shyS, COURT STAFF) (Filed on 3/18/2015)

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DANIEL H. BOOKIN (S.B. #78996)
[e-mail]

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KATHERINE L. WAWRZYNIAK (S.B. #252751)
[e-mail]

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IAN A. KANIG (S.B. #295623)
[e-mail]

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SARAH H. TRELA (S.B. #293089)
[e-mail]

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O’MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Edward T. Furnace

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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EDWARD T. FURNACE,

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Plaintiff,
v.
K. NUCKLES, et al.,
Defendants.

Case No. C 09-6075 MMC (EDL)
STIPULATION AND ____________
[PROPOSED]
ORDER ENLARGING TIME TO FILE
STIPULATION/PROPOSED ORDER
RESOLVING PLAINTIFF’S PENDING
MOTION TO COMPEL COMPLIANCE
WITH SUBPOENA TO CALIFORNIA
DEPARTMENT OF CORRECTIONS
AND REHABILITATION

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Pursuant to L.R. 6-1(b), 6-2(a), and 7-12.
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Magistrate: Hon. Elizabeth D. Laporte
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Initial Complaint Filed: December 30, 2009
Operative Complaint Filed: July 10, 2010

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STIP. & [PROPOSED] ORDER
ENLARGING TIME TO FILE
NO. C 09-6075 MMC (EDL)

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STIPULATION TO ENLARGE TIME TO FILE STIPULATION/PROPOSED ORDER

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RESOLVING PLAINTIFF’S PENDING MOTION TO COMPEL

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Plaintiff’s Motion to Compel Compliance with Subpoena to the California Department of

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Corrections and Rehabilitation (“Motion”) is currently pending. Plaintiff’s and the California

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Department of Corrections and Rehabilitation’s (“CDCR”) current deadline to file a stipulation or

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proposed order resolving Plaintiff’s Motion is Friday, March 20, 2015. See Docket No. 268.

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CDCR and Plaintiff have agreed to stipulate to change the deadline for the joint filing

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from March 20, 2015 to March 27, 2015. The extra week will accommodate CDCR’s counsel’s

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schedule, give Plaintiff’s counsel additional time to review and analyze CDCR’s February 23,

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2015 production, and enable Plaintiff and CDCR to continue to meet and confer regarding

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CDCR’s response to Plaintiff’s subpoena. (Declaration of Daniel H. Bookin (“Bookin Decl.”) ¶

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2, filed concurrently herewith.) While there have previously been multiple time modifications in

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connection with the Motion, this requested enlargement will have no apparent effect on the

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schedule for this case. (Id. ¶ 3.)

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Under Civil Local Rules 6-2 and 7-12, Plaintiff and CDCR submit this stipulation and
proposed order.
IT IS SO STIPULATED.

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STIP. & [PROPOSED] ORDER
ENLARGING TIME TO FILE
NO. C 09-6075 MMC (EDL)

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Respectfully submitted
Dated: March 17, 2015

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O’MELVENY & MYERS LLP
By:

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/s/ Daniel H. Bookin
Daniel H. Bookin

Daniel H. Bookin
Katherine L. Wawrzyniak
Ian A. Kanig
Sarah H. Trela
O’MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff

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Dated: March 17, 2015

REILY & JEFFERY, INC.
By:

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/s/ Janine K. Jeffery
Janine K. Jeffery

Janine K. Jeffery
REILY & JEFFERY, INC.
19839 Nordhoff Street
Northridge, CA 91324
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for CDCR

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STIP. & [PROPOSED] ORDER
ENLARGING TIME TO FILE
NO. C 09-6075 MMC (EDL)

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___________
[PROPOSED] ORDER ENLARGING TIME TO FILE

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STIPULATION/PROPOSED ORDER RESOLVING PLAINTIFF’S MOTION

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The Court, having considered the above Stipulation of Plaintiff and CDCR and good

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cause appearing therefor, hereby orders as follows:
Plaintiff and CDCR’s deadline to file a stipulation or proposed order resolving Plaintiff’s
Motion is extended from March 20, 2015 to March 27, 2015.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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March 18, 2015
Dated: _________________________
By:
Hon. Elizabeth D. Laporte
District Court Magistrate Judge

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STIP. & [PROPOSED] ORDER
ENLARGING TIME TO FILE
NO. C 09-6075 MMC (EDL)