Sanchez v. Andruss et al

Filing 52

STIPULATION TO CONTINUE HEARING ON DEFENDANTS' MOTION FOR SUMMARY JUDGMENT, TO EXTEND TIME FOR RESPONSE, REPLY. The hearing on the motion for summary judgment is continued from March 15, 2013 to April 26, 2013. The response is due April 6, 2013; the reply is due April 12, 2013. Signed by Judge Maxine M. Chesney on February 19, 2013. (mmclc2, COURT STAFF) (Filed on 2/19/2013)

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Jeff Dominic Price, Esq.
Attorney at Law SBN 165534
1512 16th Street, Suite 2
Santa Monica, California 90404
[e-mail]
Tel. [phone]
Fax [phone]

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Attorney for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JULIO CESAR SANCHEZ,

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Plaintiff,

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vs.

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DALLAS ANDRUSS et al.,

No. CV-10-03213-MMC
STIPULATION TO CONTINUE
HEARING ON DEFENDANTS’
MOTION FOR SUMMARY
JUDGMENT, TO EXTEND TIME
FOR RESPONSE, REPLY

Defendants.
The parties, through their counsel of record, have met and conferred. In the
interests of justice and judicial economy the parties have stipulated that the hearing
on the Motion for Summary Judgment should be continued to April 26, 2013, that
the response to the Motion for Summary Judgment should be due April 5, 2013,
and that the Reply should be due April 12, 2013. The parties stipulate to this
schedule because the plaintiff did not receive the motion papers until on or after
February 5, 2013. In addition, counsel for plaintiff needs substantial time to
transmit declarations back and forth to his client in time to file a response to the
Motion for Summary Judgment. Also, counsel for plaintiff is seeking permission to
depose defendant Andruss in a separate filing, and counsel for plaintiff may need
to request permission to conduct a deposition or depositions in order to defend
against the summary judgment motion. Additionally, there is a distinct possibility
that the parties can agree to narrow down the issues presented in the Motion for

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1 - STIPULATION TO CONTINUE SUMMARY JUDGMENT HEARING

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Summary Judgment if additional time is afforded counsel for plaintiff to review the

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motion and discuss it with the plaintiff. Thus, the parties stipulate to the

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continuance of the Motion for Summary Judgment hearing date and the filing dates

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for the response and the reply, in addition to the date for the settlement conference

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until a time after the issuance of the ruling on the defense summary judgment

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motion.

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Thus, the parties stipulate to the continuance of the hearing on the Motion
for Summary Judgment, now set for March 15, 2013, to April 26, 2013.
IT IS SO STIPULATED.

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Dated: February 15, 2013

/s/ by Jeff Price by permission
Julianne Mossler
Deputy Attorney General for Defendants

Dated: February 15, 2013

/s/ Jeff Price
Jeff Price
Attorney for Plaintiff Sanchez

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PURSUANT TO General Order 45, § 10(B), counsel for plaintiff hereby attests
that Ms. Mossler gave permission to electronically sign this stipulation on her
behalf.
IT IS SO ORDERED

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February 19, 2013
Dated: _______________

UNITED STATES JUDGE MAXINE M. CHESNEY

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