Narog v. City of Redwood City et al

Filing 78

Order by Magistrate Judge Donna M. Ryu granting as modified 77 Stipulation.(dmrlc2, COURT STAFF) (Filed on 9/22/2014)

Case4:13-cv-03237-DMR Document77 Filed09/22/14 Page1 of 3

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JIVAKA CANDAPPA (SBN 225919)
739 East Walnut Street, Suite 204
Pasadena, CA 91101
Telephone: [phone]
[e-mail]
Attorney for Plaintiff CORY NAROG

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JOSEPH C. HOWARD, JR. (SBN 050784)
[e-mail]
TODD H. MASTER (SBN 185881)
[e-mail]
MELISSA HOLMES (SBN 220961)
[e-mail]
HOWARD ROME MARTIN & RIDLEY LLP
1775 Woodside Road, Suite 200
Redwood City, CA 94061
Telephone:
[phone]
Facsimile:
(650) 364-529
Attorneys for Defendants CITY OF REDWOOD CITY,
KENNETH FALJEAN, JOHN PAUL GARY, VICTOR
F. FIGUEROA, and ASHLEY OSBORNE

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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)
)
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Plaintiff,
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vs.
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CITY OF REDWOOD CITY, OFFICER
)
VICTOR FIGUEROA (#387), OFFICER
)
KENNETH FALJEAN (#309), OFFICER
)
JEAN PAUL GARY (#288), SERGEANT
)
ASHLEY OSBORNE (#370), DOE 2 through
)
DOE 40, in their official and individual
)
capacities,
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Defendants.
)
CORY NAROG,

Case No. C13-3237 DMR
STIPULATION AND [PROPOSED]
ORDER EXTENDING THE DEADLINE
TO FILE JOINT LETTER BRIEFS TO
COMPEL, IF NECESSARY
Judge: Hon. Donna M. Ryu
Location: 1301 Clay Street, Oakland, CA
Courtroom: 4, 3rd Floor,
Trial Date: January 26, 2015

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STIPULATION AND [PROPOSED] ORDER
EXTENDING THE DEADLINE TO FILE JOINT
LETTER BRIEFS TO COMPEL, IF NECESSARY.

NAROG V. CITY OF REDWOOD CITY ET AL.
CASE NO. C13-3237 DMR

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Case4:13-cv-03237-DMR Document77 Filed09/22/14 Page2 of 3

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IT IS HEREBY STIPULATED AND AGREED, by and between the parties to this
action, through their respective counsel of record, as follows:
Discovery closed on September 16, 2014, and pursuant to the relevant local rule of court

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the current deadline to file discovery motions is September 23, 2014. Plaintiff and Defendants

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are meeting and conferring regarding: Plaintiff’s responses to Defendants’ written discovery;

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Plaintiff’s responses to the request for production of documents served with his deposition

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notice, and Defendants’ responses to Plaintiff’s request for production of documents. The

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parties respectfully request an extension of the deadline to file joint letter briefs in connection

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with the disputed discovery to September 30, 2014.

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There is good cause for the extension because the responses at issue were only recently

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received by counsel for the respective parties. The parties are attempting to meet and confer in

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an effort to narrow the issues and to resolve the matter informally without this Court’s

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intervention. The five court-day extension will not have any effect on the upcoming court

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deadlines or the trial date.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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LAW OFFICE OF JIVAKA CANDAPPA
DATED: September 22, 2014

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HOWARD ROME MARTIN & RIDLEY, LLP

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By: ________/s/_________________________________
Jivaka Candappa, Attorney for Plaintiff

DATED: September 22, 2014

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//

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//

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//

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By: ________/s/____________________________
Joseph C. Howard, Jr.
Todd H. Master
Melissa M. Holmes
Attorneys for Defendants

//

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STIPULATION AND [PROPOSED] ORDER
EXTENDING THE DEADLINE TO FILE JOINT
LETTER BRIEFS TO COMPEL, IF NECESSARY.

NAROG V. CITY OF REDWOOD CITY ET AL.
CASE NO. C13-3237 DMR

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Case4:13-cv-03237-DMR Document77 Filed09/22/14 Page3 of 3

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ORDER

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PURSUANT TO THE PARTIES’ STIPULATION, IT IS HEREBY ORDERED THAT:

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the deadline for bringing joint letter briefs to compel is extended from September 23,

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TThe parties are cautioned that the court will not
2014 to September 30, 2014. The parties are cautioned that the court will not be hearing

IT IS

motions to compel on to compel on shortened time due
be hearing motions shortened time based on the imminent
deadline imminent deadline for filing dispositive
SO ORDERED. to the for filing dispositive motions.
motions.

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Dated: September 22, 2014

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HON. DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND [PROPOSED] ORDER
EXTENDING THE DEADLINE TO FILE JOINT
LETTER BRIEFS TO COMPEL, IF NECESSARY.

NAROG V. CITY OF REDWOOD CITY ET AL.
CASE NO. C13-3237 DMR

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