Valdez et al v. City of San Jose et al

Filing 262

STIPULATION AND ORDER (as modified by the Court) granting 261 Stipulation to Continue June 30 trial date. Signed by Judge Kandis A. Westmore on 05/28/2014. (kawlc2S, COURT STAFF) (Filed on 5/28/2014)

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M. JEFFERY KALLIS, Esq. SBN 190028
The Law Firm of

Kallis & Assoc. p.c.

River Park Tower
333 W. San Carlos St., 6th Floor
San Jose, California 95110
Tel: [phone]
Fax: [phone]
[e-mail]
STEVEN M. BERKI, Esq., SBN 212434
BUSTAMANTE & GAGLIASSO P.C.
River Park Tower
333 W. San Carlos St., 6th Floor
San Jose, California 95110
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiffs

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ARDELL JOHNSON, Chief Deputy City Attorney, SBN 95340
CLIFFORD GREENBERG, Senior Deputy City Attorney, SBN 122612
San Jose City Attorney’s Office
200 East Santa Clara Street
San Jose, CA 95113- 1905
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Defendants
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
Francisco Valdez, et al.,
Plaintiffs,
vs.
City of San Jose, et al.,
Defendants.

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Valdez et al. v. City of San Jose et al.
Case No. C09- 00176KAW

) Case No. C09- 00176KAW
)
) STIPULATION AND PROPOSED ORDER FOR CONTINUING
) TRIAL DATE as modified by the Court
)
)
) Trial: June 30, 2014
)
)
)
)

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TO THE HONORABLE COURT:
The parties to this action, by and through their attorneys of record, Ardell Johnson for

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defendants and Jeff Kallis for plaintiffs, hereby stipulate as follows:

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1.

On April 7, 2014 upon the Defendant’s request, the stipulating parties agreed upon

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continuing the Martinez trial to a later date.

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2.

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On May 6, 2014, the Court was contacted and agreed to September 22, 2014 as the new date

for the Martinez trial.

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3.

On May 6, 2014, the Plaintiffs were notified and agreed to September 22, 2014 as the new

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date for the Martinez trial.

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4.

In accordance with the Defendant’s request for continuance of the trial dates and Plaintiff’s

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agreement thereto, Plaintiff’s counsel made other commitments during the time of the original trial
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dates.

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5.

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Defendants have not yet filed the stipulation for continuance of trial with the Court and have

suddenly become available for the original trial date.

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6.

Plaintiff’s counsel is unable to change the newly scheduled commitments.

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7.

Accordingly, the parties request that the trial of this matter be extended from June 30, 2014,

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to September 22, 2014 as previously agreed to by opposing counsel and the Court.

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Date: May 22, 2014

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The Law Firm of Kallis & Associates, p.c.
______/s/______________________________
M. Jeffery Kallis, for Plaintiffs

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Date: May 22, 2014

BUSTAMANTE & GAGLIASSO, P.C.
_____/s/_______________________________
Steven M. Berki, for Plaintiffs

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Valdez et al. v. City of San Jose et al.
Case No. C09- 00176KAW

Page 2

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Date: May 22, 2014

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__________/s/__________________________
Ardell Johnson, for Defendants

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San Jose City Attorney’s Office

Date: May 22, 2014

San Jose City Attorney’s Office

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_________/s/___________________________
Clifford Greenberg, for Defendants

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Valdez et al. v. City of San Jose et al.
Case No. C09- 00176KAW

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Good Cause Showing, the Court Orders that the dates for Jury Trial shall be extended

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from June 30, 2014 to September 22, 2014. Should the parties need additional time they are
to submit a supplemental stipulation at least 3 Court days prior to June 30, 2014.
05/28/2014
Dated: ______________

The Honorable Kandis A. Westmore

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______________________________
Magistrate Judge
United States District Court
Northern District Of California

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Plaintiff certifies that he has received authority from the other parties to submit this Order and
Stipulation.

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Date: May 6, 2014

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The Law Firm of Kallis & Associates, p.c.
______/s/______________________________
M. Jeffery Kallis, for Plaintiffs

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Valdez et al. v. City of San Jose et al.
Case No. C09- 00176KAW

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