Bass v. City of Fremont et al

Filing 30

STIPULATION AND ORDER for Establishing Defendants' Time to Answer Original Complaint and Continuance of Case Management Conference. Case Management Statement due by 6/17/2013. Further Case Management Conference set for 6/24/2013 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 04/24/2013. (tmi, COURT STAFF) (Filed on 4/25/2013)

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Gregory M. Fox, State Bar No. 070876
Arlene C. Helfrich, State Bar No. 096461
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Harvey E. Levine, SBN 61880
CITY OF FREMONT
City Attorney’s Office
3300 Capitol Avenue
P.O. Box 5006
Fremont, CA 94537-5006
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CITY OF FREMONT, CITY OF FREMONT
POLICE DEPT., CRAIG STECKLER, JASON MACCIOLA,
and CHRIS ALBERTI
Panos Lagos, Esq.
LAW OFFICES OF PANOS LAGOS
5032 Woodminster Lane
Oakland, CA 94602
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff
SEYLON DERRICK BASS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SEYLON DERRICK BASS,
Plaintiff,

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v.

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CITY OF FRFEMONT, et al.,

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Case No. CV12-04943-TEH
STIPULATION AND [PROPOSED] ORDER FOR
ESTABLISHING DEFENDANTS’ TIME TO
ANSWER ORIGINAL COMPLAINT AND
CONTINUANCE OF CMC DATE

Defendants.

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The Court granted in part and denied in part Defendants’ Motion to Dismiss and gave plaintiff

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until April 5, 2013 to file an amended complaint. Plaintiff declined to file an amended complaint and

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defendants are prepared to file an Answer to the remaining allegations of the initial complaint. The
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STIPULATION AND [PROPOSED] ORDER FOR ESTABLISHING DEFENDANTS’ TIME TO ANSWER ORIGINAL
COMPLAINT AND CONTINUANCE OF CMC DATE

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parties have agreed on a Court Ordered Mediation which is to occur on Thursday, May 30, 2013. To

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further economize plaintiff has graciously agreed that the defendants may defer filing their answer until

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June 20, 2013 to allow time for the Mediation process to continue to completion and a hopeful resolution

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of the case. The parties further agree, stipulate and respectfully request that the next Case Management

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Conference be continued from Monday, June 10 to Monday, June 24, so if the case does not settle, the

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defendants have time to properly prepare and file their answer and the parties to properly prepare and file

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a joint CMC statement before the CMC.

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So Stipulated:

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I declare that I have received authorization from Mr. Lagos to show his consent to this Stipulation

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by showing his signature as /s/ on this pleading.

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Dated: April 23, 2013

BERTRAND, FOX & ELLIOT

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By:

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/s/
Gregory M. Fox
Attorney for Defendants

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Dated: April 23, 2013

LAW OFFICES OF PANOS LAGOS

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By:

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/s/ Panos Lagos
Panos Lagos
Attorneys for Plaintiff

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ORDER

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Good Cause Appearing the Stipulation is So Ordered. Defendants time to Answer the Complaint

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is extended to June 20, 2013. The Case Management Conference now scheduled for Monday, June 10,

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2013 is continued to Monday June 24, 2013. A joint case management conference statement is to be
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STIPULATION AND [PROPOSED] ORDER FOR ESTABLISHING DEFENDANTS’ TIME TO ANSWER ORIGINAL
COMPLAINT AND CONTINUANCE OF CMC DATE

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filed on or before Monday, June 17, 2013.
So Ordered.

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By:

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Dated: April 24 , 2013

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United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER FOR ESTABLISHING DEFENDANTS’ TIME TO ANSWER ORIGINAL
COMPLAINT AND CONTINUANCE OF CMC DATE