Haynes v. Hanson et al

Filing 125

STIPULATION AND ORDER re 124 STIPULATION WITH PROPOSED ORDER to extend date for plaintiff's opposition filing until 9/10/14 without changes to any other dates, filed by Christian Hanson, Moseh P. Obersein. Signed by Judge Jon S. Tigar on September 2, 2014. (wsn, COURT STAFF) (Filed on 9/2/2014)

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MELINDA HAAG (CABN 132612)
United States Attorney
ALEX G. TSE (CABN 152348)
Chief, Civil Division
JONATHAN U. LEE (CABN 148792)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, CA 94102-3495
Telephone: [phone]
FAX: [phone]
[e-mail]
Attorneys for Defendant Hanson and Oberstein

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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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GREGORY HAYNES,

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Plaintiff,
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v.
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CHRISTIAN HANSON, et al.,
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Defendants.
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____________________________________)

CASE NO. 11-5021 JST
STIPULATION AND PROPOSED
ORDER

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THE UNDERSIGNED PARTIES STIPULATE AS FOLLOWS:

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1. On August 20, 2014, Defendants Christian Hanson and Moshe Oberstein filed their motion

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for summary judgment, which has a scheduled hearing date of October 2, 2014. ECF Nos.

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116-120.

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2. On August 27, 2014, Plaintiff Haynes requested an agreement from Defendants’ counsel to
extend the time for the filing of Plaintiff’s opposition from September 3, 2014 to September

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24, 2014.
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3. On August 28, 2014, Defendants’ counsel confirmed that the requested 21 day extension

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was unacceptable because it would delay the hearing on the Defendants’ motion and

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potentially endanger the pending December 1, 2014 trial date, as well as create additional
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burdens on the parties and the Court with respect to the preparation of pretrial papers in

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advance of the scheduled pretrial conference on November 14, 2014.

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4.

In light of the foregoing, Defendants informed Plaintiff that a 7 day extension on the

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deadline for the filing of Plaintiff’s opposition, namely from September 3, 2014 to

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September 10, 2014, would be acceptable to Defendants but only if the Court found it

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acceptable, the summary judgment hearing date remained intact and the other pretrial

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deadlines and trial date did not change.
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5. Therefore, the parties respectfully request that the Court permit the following to the

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deadlines applicable to the motion for summary judgment.

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Last day for Plaintiff to file any opposition to the motion:

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Last day for Defendants to file any reply to Plaintiff’s opposition: September 17, 2014

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Hearing date and location:

September 10, 2014

October 2, 2014, at 2:00 p.m. in Courtroom 9, 19th Floor, 450

Golden Gate Avenue, San Francisco, CA 94102.

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All other case management dates remain unchanged.
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IT IS SO STIPULATED.

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DATED:

August 28, 2014

_/s/_____________
_______.
Plaintiff Gregory M. Haynes

DATED:

August 28, 2014

_/s/___________________________.
Assistant U.S. Attorney Jonathan U. Lee
Attorneys for Defendants Hanson and
Oberstein

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(PROPOSED) ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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Last day for Plaintiff to file any opposition to the motion:

September 10, 2014

Last day for Defendants to file any reply to Plaintiff’s opposition: September 17, 2014
Hearing date: October 2, 2014, at 2:00 p.m. in Courtroom 9, 19th Floor, 450 Golden Gate

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Avenue, San Francisco, CA 94102.

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All other case management dates remain unchanged.

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ER

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R NIA

i ga r

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n S. T
J u d ge J o

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Hon. JON S. TIGAR
United States District Judge

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DATED: September 2, 2014
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D
RDERE
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