Wasserman v. United States

Filing 12

STIPULATION AND ORDER re 11 Proposed Order to continue the CMC, filed by United States. Case Management Statement due by 1/31/2012. Case Management Conference set for 2/7/2012 09:00 AM in Courtroom E, 15th Floor, San Francisco.. Signed by Judge Elizabeth D Laporte on 11/23/2011. (kns, COURT STAFF) (Filed on 11/23/2011)

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MELINDA HAAG (CSBN 132612)
United States Attorney
JOANN M. SWANSON (CSBN 88143)
Chief, Civil Division
MICHAEL T. PYLE (CSBN 172954)
Assistant United States Attorney
150 Almaden Blvd., Suite 900
San Jose, California 95113
Telephone: [phone]
FAX: [phone]
[e-mail]

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Attorneys for Defendant United States of America

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Michael Cohen (CSBN 98066)
Attorney at Law
Grove Law Building
345 Grove Street
San Francisco, CA 94102
415/861-4414
Fax: [phone]

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Attorney for Plaintiff David Wasserman

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION
DAVID WASSERMAN,

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Plaintiff,
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v.
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UNITED STATES OF AMERICA,
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Defendant.
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_______________________________________)

Case No. C 11-2772 EDL
STIPULATION AND [PROPOSED] ORDER
SETTING BRIEFING SCHEDULE AND
CONTINUING INITIAL CASE
MANAGEMENT CONFERENCE
AS MODIFIED

The parties, having both previously consented to allow the Court to conduct all further proceedings
in this matter, have reached the following stipulation, all of which is subject to the Court’s approval.

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Counsel for defendant has advised counsel for planitiff of defendant’s intention to file a motion to

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dismiss the complaint. This motion will be filed on or before November 30, 2011, a few days prior to

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the deadline to respond to the complaint because of leave long scheduled for defendant’s counsel. The

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parties have discussed a briefing schedule to accomodate their respective schedules and which they

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believe is most efficient for their respective clients.
No. C 11-2772 EDL STIPULATION AND [PROPOSED]
ORDER SETTING BRIEFING SCHEDULE AND CONTINUING CMC

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Defendant will notice his motion for hearing on February 7, 2012 at 9:00 a.m. The parties have

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agreed that Plaintiff will have until January 6, 2012 to file any opposition papers and Defendant will

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have until January 20, 2012 to file any reply papers. The parties have further stipulated to request that

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the Court continue the Initial Case Management Conference from December 20, 2011 to February 7,

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2012 at 10:00 a.m., the same day as the motion hearing date.

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DATED: November 16, 2011

Respectfully submitted,

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MELINDA HAAG
United States Attorney

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/s/ Michael T. Pyle
________________________________
MICHAEL T. PYLE
Assistant United States Attorney
Counsel for Defendant United States of America

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/s/ Michael Cohen
________________________________
MICHAEL COHEN
Attorney at Law
Counsel for Plaintiff David Wasserman

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PURSUANT TO STIPULATION, IT IS SO ORDERED:
Defendant’s motion to dismiss is to be filed on or before November 30, 2011. Planitiff’s
opposition to the motion is due on or before January 6, 2012. Defendant’s reply in support of the
motion is due on or before January 20, 2012. Defendant shall notice the motion for hearing on
February 7, 2012 at 9:00 a.m. The Court reserves the right to continue the hearing or decide the motion
without a hearing should the Court decide that it is appropriate to do so. The initial Case Management
9:00

Conference is continued from December 20, 2011 to February 7, 2012 at 10:00 a.m. The parties shall
file a joint Case Management Conference Statement on or before January 31, 2012.

November 23, 2011
Dated: _________________

____________________________________
HON. ELIZABETH D. LAPORTE
United States Magistrate Court Judge

No. C 11-2772 EDL STIPULATION AND [PROPOSED]
ORDER SETTING BRIEFING SCHEDULE AND CONTINUING CMC

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