Lawman v. City and County of San Francisco et al

Filing 45

Order by Magistrate Judge Donna M. Ryu granting 44 Motion for Leave to File Excess Pages.(dmrlc1, COURT STAFF) (Filed on 11/20/2015)

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Joseph S. May SBN 245924
LAW OFFICE OF JOSEPH S. MAY
1388 Sutter Street, Suite 810
San Francisco, CA 94109
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Plaintiff GARY RICHARD LAWMAN
by and through his Guardian ad Litem Richard de Villiers

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
OAKLAND DIVISION

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GARY RICHARD LAWMAN by and
through his Guardian ad Litem Richard de
Villiers,
Plaintiff,

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CASE NO. C15-01202-DMR
ADMINISTRATIVE MOTION FOR
LEAVE TO FILE MEMORANDUM IN
EXCESS OF 25 PAGES AND [PROPOSED]
ORDER

v.
CITY AND COUNTY OF SAN
FRANCISCO; PHILLIP M. GORDON;
GLEN PAUL MINIOZA; BRIAN W.
KNEUKER; CARLOS GUTIERREZ;
CRAIG F. TOM; PATRICK F. PENE;
JULIO C. PALENCIA; ANDREW N.
BROWN; PAUL E. RAPICAVOLI;
MATTHEW M. O’SHEA; MICHAEL
HENNESSEY; GREG SUHR; ROEL L.
LAPITAN; FRANK LATKO a.k.a.
FRANZI LATKO; and DOES 1 through
50, inclusive,

Hearing Date:
Time:
Place:
Judge:

Action Filed:
Removal:
Trial Date:

December 17, 2015
11:00 a.m.
Courtroom 4, 3rd Floor
Hon. Donna M. Ryu

December 31, 2013
March 13, 2015
June 6, 2016

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Defendants.
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CASE NO. C15-01202-DMR
ADMINISTRATIVE MOTION FOR LEAVE TO FILE MEMORANDUM IN EXCESS OF 25 PAGES AND [PROPOSED] ORDER

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Pursuant to Civil Local Rule 7-11, Plaintiff respectfully requests leave to file a

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memorandum opposing Defendants’ motion for summary judgment in excess of the 25-page

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limit for memorandum, set forth in Local Rule 7-4(b).

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Defendants’ motion for summary judgment, seeking judgment on each and every one of

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Plaintiff’s eight causes of action against numerous defendants, is exactly 25 pages. However,

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Defendants have omitted many crucial portions of the voluminous record developed in this case,

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which includes 12 depositions and more than 1000 pages of documents produced. In order to

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provide the Court with an accurate and complete account of the facts of the case, Plaintiff will

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likely need additional space. Also, Plaintiff will likely need more pages to present arguments

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relating to each of the several claims and defenses at issue here.

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Dated: November 19, 2015

LAW OFFICE OF JOSEPH S. MAY

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/s/ Joseph S. May
By: JOSEPH S. MAY, Attorneys for Plaintiff
GARY RICHARD LAWMAN

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DECLARATION OF JOSEPH S. MAY [Local Rule 7-11(a)]
I, Joseph S. May, declare:

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I asked the City Attorney’s office to stipulate but they refused.
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I declare under penalty of perjury under the laws of the state of California and the United
States that the foregoing is true and correct.

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Executed on November 19, 2015, at San Francisco, California.

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/s/ Joseph S. May
JOSEPH S. MAY

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CASE NO. C15-01202-DMR
ADMINISTRATIVE MOTION FOR LEAVE TO FILE MEMORANDUM IN EXCESS OF 25 PAGES AND [PROPOSED] ORDER

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[PROPOSED] ORDER

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For good cause shown, Plaintiff is hereby granted leave to file a memorandum in
opposition to the Defendants’ motion for summary judgment up to but not exceeding 30 pages.

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onna

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Judge D

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R NIA

___________________________________
HON. DONNA M. RYU
United States District Judgeu
M. Ry

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NO

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Dated: November 20, 2015

DERED

O OR
IT IS S

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UNIT
ED

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SO ORDERED.

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CASE NO. C15-01202-DMR
ADMINISTRATIVE MOTION FOR LEAVE TO FILE MEMORANDUM IN EXCESS OF 25 PAGES AND [PROPOSED] ORDER