Vargas v. Knowles

Filing 210

STIPULATION AND ORDER Granting Request an Extension of Time to File Joint Status Statement re 208 Stipulation filed by Eddie M. Vargas, Sr. Status Report due by 1/18/2012. Signed by Judge Edward J. Davila on 11/30/2011. (ecg, COURT STAFF) (Filed on 11/30/2011)

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JERRY Y. FONG, ESQ. (SBN 99673)
CAREY & CAREY
706 COWPER STREET
P.O. BOX 1040
PALO ALTO, CA 94302-1040
650/328-5510
650/853-3632 fax

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Attorneys for Petitioner EDDIE VARGAS, SR.

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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EDDIE VARGAS, SR.,
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Petitioner,
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vs.
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MIKE KNOWLES, Warden,
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Respondent.
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CASE NO.

C-03-02930 EJD

STIPULATION OF THE PARTIES TO
REQUEST ORDER EXTENDING TIME
TO FILE JOINT STATEMENT RE
STATUS OF THE CASE &
[PROPOSED] ORDER RE SAME.

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Petitioner Eddie Vargas and Respondent Mike Knowles, through their respective

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attorneys of record, hereby submit this joint stipulation to request that the Court grant an

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extension of time for the parties to work together to file a joint statement regarding the status

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of this case.

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The attorneys of the parties have been in communication over the Court’s order for

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a joint statement (to be filed on November 30, 2011), and the parties have exchanged ideas,

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including legal positions regarding the procedural posture of this matter. The parties jointly

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believe that an additional 45 days or so will be helpful to allow the parties to work on the

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joint statement and to attempt to identify and resolve, if possible, certain issues relating to

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the status of the case.

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Accordingly, the parties respectfully and jointly request that the Court extend the time
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PARTIES’ JOINT STIPULATION TO REQUEST EXTENSION OF TIME TO FILE JOINT STATEMENT RE STATUS

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to file the joint statement re status, from November 30, 2011 to January 18, 2012.

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DATED:

November 29, 2011

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Respectfully submitted,
CAREY & CAREY

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/S/
by JERRY Y. FONG, Attorney for
Petitioner EDDIE VARGAS, SR.

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DATED:

November 29, 2011

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Respectfully submitted,
THE ATTORNEY GENERAL’S OFFICE
FOR THE STATE OF CALIFORNIA

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/S/
by GREGORY A. OTT, Attorney for
Respondent MIKE KNOWLES

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[PROPOSED] ORDER
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Pursuant to the parties’ stipulation and good cause appearing herein, it is hereby
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ordered that the joint request to extend the time to file the joint status statement shall be
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granted, and the parties shall file their joint status statement by January 18, 2012. It is so
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ordered.
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DATED: November 30, 2011

JUDGE OF THE UNITED STATES
DISTRICT COURT

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PARTIES’ JOINT STIPULATION TO REQUEST EXTENSION OF TIME TO FILE JOINT STATEMENT RE STATUS