Jefferson v. City of Fremont et al

Filing 52

STIPULATION AND ORDER re 51 to Reschedule ENE Deadline, File Third Amended Complaint and Continue CMC filed by Walter Darnell Jefferson Case Management Statement due by 4/11/2013. Case Management Conference set for 4/18/2013 09:00 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 1/17/13. (bpf, COURT STAFF) (Filed on 1/17/2013)

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Angela L. Morgan, State Bar No. 208585
LOGAN LAW GROUP
2410 Camino Ramon, Suite 274
San Ramon, California 94583
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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WALTER JEFFERSON,

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Plaintiff,

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v.
THE CITY OF FREMONT, FREMONT
TENNIS CENTER, JEFF GONCE, JOE
GRECH, ANNABELLE HOLALND, KELLY
KING and Does 1 through 10, inclusive,

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STIPULATION OF COUNSEL AND PROPOSED
ORDER TO RESCHEDULE THE DEADLINE TO
COMPLETE EARLY NEUTRAL EVALUATION,
FILE THIRD AMENDED COMPLAINT AND
CONTINUE CASE MANAGEMENT
CONFERENCE ; ORDER

Defendants.

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Case No. 3:12-cv-00926 EMC

Honorable Edward M. Chen
Plaintiff Walter Jefferson and Defendants City of Fremont, a municipal public entity on behalf of
itself and the Fremont Tennis Center, Jeff Gonce, Joe Grech, Annabelle Holland, and Kelly King hereby
submit the following Stipulation and Proposed Order rescheduling the deadline to complete Early Neutral
Evaluation and to file Third Amended Complaint.
The Court ordered Early Neutral Evaluation to be completed by February 13, 2013. However,
new information pertinent to the prosecution of this action has been brought to the attention of Plaintiff.
As such, Plaintiff requires sufficient time to investigate the new claims in order to have a productive
early neutral evaluation. In an effort to not delay this case any further, Plaintiff will file his Third
Amended Complaint.
IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS:
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The deadline to complete Early Neutral Evaluation shall be rescheduled to April 29, 2013.

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Plaintiff will file his Third Amended Complaint no later than February 8, 2013.

3.

Defendants shall have until March 1, 2013 to file a responsive pleading to the Third

Amended Complaint.

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STIPULATION OF COUNSEL AND PROPOSED ORDER TO RESCHEDULE THE DEADLINE TO COMPLETE EARLY NEUTRAL
EVALUATION, TO FILE THIRD AMENDED COMPLAINT AND CONTINUE CASE MANAGEMENT CONFERENCE

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4.

The Case Management Conference shall be reset from February 28, 2013 at 9:00 a.m. to

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April 18, 2013 at 9:00 a.m.

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SO STIPULATED.

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Dated: January 14, 2013

LOGAN LAW GROUP

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By:

/S/
Angela L. Morgan
Attorney for Plaintiff
WALTER JEFFERSON

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Dated: January 15, 2013

BERTRAND, FOX & ELLIOT

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By:

/S/

Gregory M. Fox
Ilana Kohn
Attorneys for Defendants
CITY OF FREMONT, FREMONT TENNIS
CENTER, JEFF GONCE, JOE GRECH,
ANNABELLE HOLLAND and KELLY KING

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ATTORNEY ATTESTATION

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I hereby attest that I have on file all holograph signatures for any signatures indicated by a

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“conformed” signature (/s/) within this E-filed document.

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Dated: January 15, 2013

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/S/
________
Angela L. Morgan

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STIPULATION OF COUNSEL AND PROPOSED ORDER TO RESCHEDULE THE DEADLINE TO COMPLETE EARLY NEUTRAL
EVALUATION, TO FILE THIRD AMENDED COMPLAINT AND CONTINUE CASE MANAGEMENT CONFERENCE

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[PROPOSED] ORDER

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4.

The Case Management Conference shall be reset from February 28, 2013 at 9:00a.m. to

April 18, 2013 at 9:00a.m
IT IS SO ORDERED.
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Dated: January ___, 2013

S DISTRICT
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DERED

O OR
IT IS S

______________________________________
HONORABLE EDWARD CHEN
UNITED STATES DISTRICT COURT JUDGE
. Chen
dward M
Judge E

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Amended Complaint.

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Defendants shall have until March 1, 2013 to file a responsive pleading to the Third

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3.

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Plaintiff shall file his Third Amended Complaint no later than February 8, 2013.

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2.

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Early Neutral Evaluation shall be completed by April 29, 2013.

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1.

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it is hereby ORDERED as follows:

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Pursuant to the above Stipulation of the parties by and through their respective counsel of record,

UNIT
ED

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F
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STIPULATION OF COUNSEL AND PROPOSED ORDER TO RESCHEDULE THE DEADLINE TO COMPLETE EARLY NEUTRAL
EVALUATION, TO FILE THIRD AMENDED COMPLAINT AND CONTINUE CASE MANAGEMENT CONFERENCE