Teresa Aguirre v. State of California et al

Filing 163

ORDER by Judge Haywood S. Gilliam, Jr. Granting 162 Stipulation to Continue Pretrial Filing Deadline to July 25, 2018. (ndrS, COURT STAFF) (Filed on 6/5/2018)

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XAVIER BECERRA
Attorney General of California
KAREN KIYO LOWHURST
Deputy Attorney General
LISA J. PLANK
Deputy Attorney General
State Bar No. 153737
1515 Clay Street, 20th Floor
P.O. Box 70550
Oakland, CA 94612-0550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
State of California, et al.
DEBORAH KOCHAN (S.B. # 152089)
MATHEW STEPHENSON (S.B. #154330)
KOCHAN & STEPHENSON
1680 Shattuck Avenue
Berkeley, CA 94709
Telephone: [phone]
Fax: [phone]
ELIZABETH M. PECK (S.B. #277794)
PECK LAW
111 North Market St., Ste. 300
San Jose, CA 95113
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff
Teresa Aguirre

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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TERESA AGUIRRE,

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v.

4:16-cv-05564-HSG
Plaintiff, STIPULATION AND [Proposed] ORDER
TO CONTINUE PRETRIAL FILING
DEADLINE TO JULY 25, 2018

STATE OF CALIFORNIA; DEBRA
MILLS, CARIANNE HUSS; and DOES 1
through 5,

Judge:
Hon. Haywood S. Gilliam, Jr.
Trial Date:
December 3, 2018
Defendants. Action Filed: September 30, 2016

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Stipulation and [Proposed] Order to Continue Pretrial Filing Deadline to July 25, 2018 (4:16-cv-05564-HSG)

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Following extensive good faith meet and confer, the parties jointly request a one-week

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continuance of the July 18, 2018 pretrial filing deadline (for a revised statement of the case,

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revised proposed jury instructions, and revised proposed voir dire questions per Dkt. No. 161), for

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the following reasons. As reflected in Plaintiff’s trial availability schedule (Doc. 160), both

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Plaintiff’s trial counsel are on vacation July 11 through 18. As reflected in Defendants’ trial

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availability calendar (Doc. 159), defense lead counsel Lowhurst is on vacation for the period June

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1- July 11, and DAG Plank is on vacation June 14 and 15, and from July 2 through 6. Therefore,

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under the current schedule it is not possible for both lead counsel to jointly review and finalize the

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pre-trial filings before the July 18 due date. Specifically, while the parties can, and will, prepare

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draft documents in anticipation of a July 18th deadline, Defendant’s lead counsel (Lowhurst) will

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not be able to review the filings until July 12, by which time all of Plaintiff’s counsel will be

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absent. Should the Court allow, the parties stipulate to a one-week extension for the filing of the

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revised statement of the case, revised proposed jury instructions, and revised proposed voir dire

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questions, to July 25, 2018.

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Dated: June 4, 2018

Respectfully submitted,

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XAVIER BECERRA
Attorney General of California

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/s/ Lisa J. Plank

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LISA J. PLANK
Deputy Attorney General
Attorneys for Defendants
State of California, et al.

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Stipulation and [Proposed] Order to Continue Pretrial Filing Deadline to July 25, 2018 (4:16-cv-05564-HSG)

ATTESTATION

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I attest under penalty of perjury that concurrence in the filing of this document has been

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obtained from Deborah Kochan.

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Dated: June 4, 2018

Respectfully submitted,

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XAVIER BECERRA
Attorney General of California

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/s/ Lisa J. Plank

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LISA J. PLANK
Deputy Attorney General
Attorneys for Defendants
State of California, et al.

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[Proposed] ORDER

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Good cause appearing, the Stipulation Regarding Continuance of Pretrial Filing Deadline

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to July 25, 2018, is hereby approved.

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DATED:

6/5/2018

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Haywood S. Gilliam, Jr.
U.S. District Court Judge

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Stipulation and [Proposed] Order to Continue Pretrial Filing Deadline to July 25, 2018 (4:16-cv-05564-HSG)