Brock v. County of Napa

Filing 60

STIPULATION AND ORDER EXTENDING TIME TO FILE REPLY PAPERS TO MOTION FOR SANCTIONS. Signed by Judge Joseph C. Spero on 5/14/12. (klhS, COURT STAFF) (Filed on 5/14/2012)

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Gregory G. Spaulding, Esq. (SBN 106606)
Terry S. Sterling, Esq. (SBN 106379)
SPAULDING McCULLOUGH & TANSIL LLP
90 South E Street, Suite 200
P.O. Box 1867
Santa Rosa, CA 95402
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]; [e-mail]
Attorneys for Defendant
COUNTY OF NAPA

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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GAYLE BROCK,
Plaintiff,

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Case No.: CV 11-0257 SBA
STIPULATION AND [PROPOSED] ORDER
EXTENDING TIME TO FILE REPLY
PAPERS

vs.
COUNTY OF NAPA and DOES 1 through 50,
inclusive,

Date: June 15, 2012
Time: 1:30 pm
Ctrm: G, 15th Floor
Magistrate Judge Joseph C. Spero

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Defendants.
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PreTrial Conference: July 10, 2012
Trial Date: July 16, 2012

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Plaintiff GAYLE BROCK and defendant COUNTY OF NAPA ("County") hereby enter into

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this Stipulation Extending Time To File Reply Papers with reference to the following facts:

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On April 17, 2012, plaintiff filed her Motion to Preclude Defendant from Using Late

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Produced Documents at Trial; for Default or Dismissal in Favor of Plaintiff if it Pleases the Court; for

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Attorney Fees and Costs; and for Other Sanctions Deemed Appropriate by the Court ("Sanctions

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Motion"). The Sanctions Motion was originally set for hearing on May 22, 2012, but on April 24,

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2012, the Court continued the hearing date to June 15, 2012. The Court did not change the dates for

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opposition or reply papers. On May 1, 2012, the County filed its Opposition to the Sanctions Motion

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based on the briefing schedule mandated by the original May 22, 2012 hearing date.

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The deadline for filing reply papers based on the original briefing schedule is May 8, 2012. In
order to properly address the numerous legal and factual issues raised by the Sanctions Motions,
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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE REPLY PAPERS

Case No. CV 11-0257 SBA

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plaintiff requires additional time to file her reply papers. In light of the continuance of the hearing

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date for the Sanctions Motion, the requested extension of the deadline for filing reply papers will not

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unduly limit the time available for the Court to prepare for the hearing on the Motion.

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IT IS HEREBY STIPULATED by and between plaintiff GAYLE BROCK and defendant

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COUNTY OF NAPA, through their attorneys of record, that the deadline for reply papers to be filed

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in connection with the Sanctions Motion shall be continued to May 11, 2012.

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DATED: May 4, 2012

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SPAULDING McCULLOUGH & TANSIL LLP
Attorneys for Defendant
COUNTY OF NAPA

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By:

/s/ Terry S. Sterling
Terry S. Sterling

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DATED: May 4, 2012

LAW OFFICE OF JESSE S. TURNER
Attorneys for Plaintiff GAYLE BROCK

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By:
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/s/ Jesse S. Turner
Jesse S. Turner, Esq.

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE REPLY PAPERS

Case No. CV 11-0257 SBA

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U.S. DISTRICT COURT MAGISTRATE JUDGE
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Judge Jo

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5/14/12

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DATED:

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UNIT
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IT IS SO ORDERED.

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[PROPOSED] ORDER

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STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE REPLY PAPERS

Case No. CV 11-0257 SBA