Richard Flemming v. County of Alameda, et al.

Filing 49

STIPULATION AND ORDER to Continue Case Management Conference. Case Management Statement due by 11/16/2015. Further Case Management Conference set for 11/23/2015 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 09/23/2015. (tmiS, COURT STAFF) (Filed on 9/23/2015) Modified on 9/23/2015 (tmiS, COURT STAFF).

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Autumn R. Paine, State Bar No. 251038
LAW OFFICE OF AUTUMN R. PAINE
385 Grand Avenue, Suite 200
Oakland, California 94610
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorney for Plaintiff
RICHARD FLEMMING
Thomas F. Bertrand, State Bar No. 056560
Michael C. Wenzel, State Bar No. 215388
Amy Leifur Halby, State Bar No. 287216
BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant
COUNTY OF ALAMEDA and GREGORY AHERN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RICHARD FLEMMING

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Plaintiff,

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v.

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Case No. 3:14-cv-05542-TEH

STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE; [PROPOSED
ORDER]

COUNTY OF ALAMEDA, et al.
Defendants.
Hon. Thelton E. Henderson
STIPULATION
Defendants COUNTY OF ALAMEDA and GREGORY AHERN and plaintiff RICHARD
FLEMMING, by and through their respective attorneys of record, hereby stipulate as follows:

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Flemming v. County of Alameda, et al.; USDC Northern District of CA Case No. 3:14-cv-05542-TEH

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1.

By Order dated August 3, 2015, this matter was scheduled by the Court for a Case

Management Conference to be held on November 9, 2015. (Docket No. 47.)

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2.

Prior to the Court’s Order scheduling the Case Management Conference, defense counsel

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had scheduled and paid for a family vacation out of state from November 5, 2015 through November 10,

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2015.

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3.

Given the unavailability and inability of defense counsel to appear at the presently

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scheduled Case Management Conference, the parties request that the Court continue the Case

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Management Conference in this matter scheduled for November 9, 2015 to November 23, 2015 or a date

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as soon thereafter as is convenient to the Court, other than November 30, 2015 as defense counsel has

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been called for jury duty on that date.
4.

For all the good cause stated above, the parties respectfully request this Court continue the

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Case Management Conference scheduled for November 9, 2015 to November 23, 2015 or a date as soon

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thereafter as is convenient to the Court, other than November 30, 2015 as defense counsel has been called

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for jury duty on that date. The parties do not request the modification of any other dates.

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5.

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terms in an Order.

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The parties respectfully request that the Court approve this stipulation and incorporate its

IT IS SO STIPULATED.

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Dated: September 21, 2015

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LAW OFFICE OF AUTUMN R. PAINE
By:

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/s/Autumn Paine
Autumn Paine
Attorney for Plaintiff
RICHARD FLEMMING

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Dated: September 21, 2015

BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
By:

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/s/Michael C. Wenzel
Michael C. Wenzel
Attorneys for Defendants
COUNTY OF ALAMEDA
and GREGORY AHERN

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Flemming v. County of Alameda, et al.; USDC Northern District of CA Case No. 3:14-cv-05542-TEH

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[PROPOSED] ORDER

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GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the

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parties’ stipulation is hereby APPROVED. The Case Management Conference scheduled for November

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November 23
1:30 PM
9, 2015 at 1:30 p.m. is continued to ________________, 2015 at ___________.
IT IS SO ORDERED.

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09/23/2015

THELTON E. HENDERSON
United States District Court Judge

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Flemming v. County of Alameda, et al.; USDC Northern District of CA Case No. 3:14-cv-05542-TEH