Passakos et al

Filing 22

ORDER Granting 20 Stipulation to Continue Case Management Conference. Case Management Statement due by 8/2/2011. Case Management Conference set for 8/9/2011 02:00 PM. Signed by Judge Claudia Wilken on 6/23/2011. (ndr, COURT STAFF) (Filed on 6/23/2011)

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SANFORD M. CIPINKO, Esq., SBN 88102
2 YULIYA MAGOMEDOV, Esq., SBN 251964
LAW OFFICES OF SANFORD M. CIPINKO
3 55 FRANCISCO STREET, SUITE 403
SAN FRANCISCO, CA 94133
4 VOICE:
[phone]
FACSIMILE: [phone]
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Attorneys for Plaintiff
6 GIANNI PASSAKOS
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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11 GIANNI PASSAKOS,
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Plaintiff,

13 vs.
14 COUNTY OF ALAMEDA; and DOES 150,
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Defendants.
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Case No.: C10-04062 CW
STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
ORDER

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The undersigned hereby stipulate as follows:

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This lawsuit arises from a physical altercation between the plaintiff and deputy

19 sheriffs which occurred at the Santa Rita jail. The plaintiff has been charged with a
20 violation California Penal Code § 148 as a result of that altercation. That criminal action
21 is presently pending and has been set for trial in June 2011. While the criminal action is
22 pending, plaintiff will not testify to any issues related to the altercation which is the subject
23 of both actions.
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Plaintiff’s counsel of record in this action, Sanford Cipinko, Esq., was on medical

25 leave for a month and scaled back his law practice.

As a result, he can no longer

26 represent the plaintiff in this action, and has been assisting the plaintiff to find new
27 counsel. However, to date and to the best of plaintiff’s counsel’s knowledge, plaintiff has
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-1STIPULATION TO CONT. CASE MANAGEMENT CONFERENCE AND ORDER
Gianni Passakos vs. County of Alameda; USDC-Nor. Dist of CA Case No. C10-04062 CW

1 been unable to find new counsel to represent him in this action. Thus, Plaintiff’s counsel
2 is filing a Motion to Withdraw as Attorney of Record concurrently with this Stipulation.
3

For the forgoing reasons, the parties hereby request that the court continue the

4 case management conference set for June 28, 2011 at 2:00 p.m. to August 9, 2011 at
5 2:00 p.m. until after the Plaintiff’s counsel’s Motion to Withdraw has been heard.
6 DATED: June 21, 2011
LAW OFFICES OF SANFORD M. CIPINKO

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10 DATED: June 21, 2011
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By: /s/Sanford M. Cipinko____________
SANFORD M. CIPINKO, ESQ.
Attorneys for Plaintiff
BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation

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By: /s/Gregory J. Rockwell1_____________
GREGORY J. ROCKWELL, ESQ.
Attorneys for Defendant
COUNTY OF ALAMEDA

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ORDER

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Good Cause appearing therefore, the Case Management Conference set for June

19 28, 2011 at 2:00 p.m. in action 10-04062CW is hereby continued to August 9, 2011 at
20 2:00 p.m. The parties shall file a joint case management conference statement no later
21 than August 2, 2011.
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Dated: 6/23/2011
____________________________________
CLAUDIA WILKEN
United States District Judge

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1

Defendant’s counsel agree to this stipulation and authorized defense counsel to place his electronic
signature on this stipulation.
-2STIPULATION TO CONT. CASE MANAGEMENT CONFERENCE AND ORDER
Gianni Passakos vs. County of Alameda; USDC-Nor. Dist of CA Case No. C10-04062 CW

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PROOF OF SERVICE BY ELECTRONIC SERVICE

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3

I am a resident of the State of California, over the age of 18 years and not a party

4 to the within action. My business address is Law Offices of Sanford M. Cipinko, 55
5 Francisco Street, Suite 403, San Francisco, California 94133.
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On the date indicated below, at the above-referenced business location, I served

7 the STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND
8 ORDER on the below-named party and caused said document to be transmitted using
9 ECF as specified by General Order No. 45 to the following party:
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GREGORY J. ROCKWELL, ESQ.
[e-mail]
JILL P. SAZAMA, ESQ.
[e-mail]
BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation/File
#26525
555 12th Street, Suite 1800
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]

Attorneys for Defendant

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I declare under penalty of perjury under the laws of the State of California that the

18 foregoing is true and correct.
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Executed at San Francisco, California, on June 21, 2011.

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Jack LaFrancesca
Jack LaFrancesca

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-3STIPULATION TO CONT. CASE MANAGEMENT CONFERENCE AND ORDER
Gianni Passakos vs. County of Alameda; USDC-Nor. Dist of CA Case No. C10-04062 CW