Hernandez et al v. County of Marin et al

Filing 96

STIPULATION AND ORDER re 95 STIPULATION WITH PROPOSED ORDER re 87 MOTION for Summary Judgment or in the Alternative Partial Summary Judgment, filed by Keith Boyd, County of Marin. Signed by Judge Jon S. Tigar on June 10, 2013. (wsn, COURT STAFF) (Filed on 6/10/2013)

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STEVEN WOODSIDE, COUNTY COUNSEL
Renee Giacomini Brewer, SBN 173012
3501 Civic Center Drive, Room 275
San Rafael, CA 94903
Tel.: [phone], Fax: [phone]
Attorney(s) for the Defendant COUNTY OF MARIN

Thomas F. Bertrand, SBN056560
Richard W. Osman, SBN167993
BERTRAND, FOX & ELLIOT
2749 Hyde Street
San Francisco, Ca 94109
Attorneys for Defendants
CITY OF SAN RAFAEL AND TWIN
CITIES POLICE AUTHORITY

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OWEN MAYER
P.O. Box 4213
San Rafael, CA 94913
Attorney for PLAINTIFFS

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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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JOSE HERNANDEZ, ALMA HERNANDEZ,
JOSH HERNANDEZ, individually and as a
guardian ad litem for TAMMY HERNANDEZ, a
minor,

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STIPULATION AND ORDER REQUESTING
CHANGE OF DATE OF MOTION FOR
SUMMARY JUDGMENT

Plaintiffs,

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Case No.: CV 11 3085 JST

v.

Civil Local Rule 7-7
Honorable Jon S. Tigar

COUNTY OF MARIN, CITY OF SAN RAFAEL,
CITY OF LARKSPUR, TOWN OF CORTE
MADERA, TWIN CITIES POLICE
DEPARTMENT and DOES 1-100, inclusive,
Defendants.

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By this pleading, Plaintiffs Jose Hernandez, Alma Hernandez, Josh Hernandez and Tammy

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Hernandez (“Plaintiffs”) and Defendants County of Marin and Keith Boyd (collectively, “COM

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Defendants”) and Defendants City of San Rafael, Twin Cities Police Authority, Wanda Spaletta and

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Anthony Shaw (collectively, “City Defendants), by and through their respective counsel, hereby

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stipulate and agree that COM’s Motion for Summary Judgment or in the Alternative Partial Summary

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Judgment date be modified and changed to August 5, 2013.

Hernandez v. County of Marin, et al.
CV 11-3085 JST
Joint Stipulation
56878

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Good cause exists for the rescheduling because: (1) on March 14, 2013, this Court ordered the last

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day for dispositive motions to be heard as July 15, 2013; (2) on June 6, 2013, COM Defendants filed a

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Motion for Summary Judgment with a hearing date of July 11, 2013; (3) subsequently on June 6, 2013, this

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Court rescheduled the Summary Judgment hearing for July 18, 2013; (4) because the last date for the

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Summary Judgment Motion had previously been set by this Court as July 15, 2013, Counsel for COM

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purchased tickets and will be out of the country on July 18, 2013; and (5) no trial date is currently set in this

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matter. All parties agree to continue the Summary Judgment Motion hearing date as indicated.

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IT IS SO STIPULATED.
Date: June 10, 2013

by:___________________-s-_______________
Owen Mayer, Attorney for Plaintiffs

Date: June 10, 2013

by:__________________-s-_________________
Renee Giacomini Brewer, Attorney for Defendants
County of Marin

Date: June 10, 2013

by:___________________-s-_______________
Rich Osman, Attorney for Defendants
City of San Rafael, City of Larkspur

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[PROPOSED] ORDER
Based on the foregoing Stipulation and for good cause shown, the Court hereby accepts the Parties’
Stipulation and ORDERS the following date for Motion for Summary Judgment and in the Alternative

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Partial Summary Judgment: August 15, 2013 at 2:00 p.m.

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August 5, 2013

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IT IS SO ORDERED.

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Dated: June 10, 2013

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______________________________________________
THE HONORABLE JON S. TIGAR
UNITED STATES DISTRIRCT COURT JUDGE

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Hernandez v. County of Marin, et al.
CV 11-3085 JST
Joint Stipulation
56878

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