Palladini v. City of Milpitas et al

Filing 83

STIPULATION AND ORDER for extension of time for Discovery re 81 Stipulation filed by Frank Palladini. Close of Discovery set for 12/1/2008. This extension does not modify any other deadlines or hearings set by the Court. Signed by Judge James Ware on 10/14/2008. (ecg, COURT STAFF) (Filed on 10/14/2008)

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James M. Barrett (SBN: 190274) Email: [e-mail] LAW OFFICE OF JAMES M. BARRETT 789 Castro Street Mountain View, CA 94041 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff FRANK PALLADINI, dba LITTLE FRANKS BAR & GRILL Kimberly E. Colwell (SBN: 127604) Email: [e-mail] Tricia L. Hynes (SBN: 212550) Email: [e-mail] MEYERS, NAVE, RIBACK, SILVER & WILSON 555 12th Street, Suite 1500 Oakland, CA 94607 Telephone: [phone] Facsimile: [phone]

Montgomery S. Pisano (SBN: 205230) Email: [e-mail] PENINSULA LAW GROUP, APLC 789 Castro Street Mountain View, CA 94041 Telephone: [phone] Attorneys for Plaintiff FRANK PALLADINI, dba LITTLE FRANKS BAR & GRILL

Attorneys for Defendants CITY OF MILPITAS; THOMAS NISHISAKA; CHARLES LAWSON; ERIC EMMANUELLE; JOHN BUCHANOK; HENRY KWONG; KEVIN MOSQUZA; DAVID MORRIS; RAJ MAHARAJ; MARK DOYLE; PHEAK KOR IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA FRANK PALLADINI, an individual, dba Little Franks Bar & Grill, v. Plaintiff, Case No: C06-00779 JW (HRL) STIPULATION AND [PROPOSED] ORDER ALLOWING EXTENSION OF TIME FOR DISCOVERY

CITY OF MILPITAS; THOMAS NISHISAKI, individually, and as his official capacity as Chief of Police; CHARLES LAWSON, individually, and as his official capacity as Chief of Police and City Manager; ERIC EMMANUELLE, individually, and as his capacity as a police officer (#178); JOHN BUCHANOK, individually, and as his capacity as a police officer (#233); HENRY KWONG, individually, and as his capacity as a police officer (#190); KEVIN MOSQUZA, individually, and as his capacity as a police officer (#211); DAVID MORRIS, individually, and as his capacity as a police officer (#235); RAJ MAHARAJ, individually, and as his capacity as a police officer (#216); MARK DOYLE, individually, and as his capacity as a police officer (#191); PHEAK KOR, individually, and as his capacity as a police officer; and DOES 1-100,

State Court Complaint Filed: December 16, 2005 Removal Filed: February 3, 2006 Trial Date: November 10, 2008

Stip & Order to Extend Discovery

Case No. C06-00779 JW

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Defendants.

Comes now PLAINTIFF FRANK PALLADINI, dba LITTLE FRANKS BAR AND GRILL (hereinafter "PLAINTIFF") and DEFENDANTS CITY OF MILPITAS, THOMAS NISHISAKA, CHARLES LAWSON, ERIC EMMANUELLE, JOHN BUCHANOK; HENRY KWONG, KEVIN MOSQUZA, DAVID MORRIS, RAJ MAHARAJ, MARK DOYLE, PHEAK KOR (hereinafter "DEFENDANTS") who submit the following Stipulation and Proposed Order: WHEREAS, The current discovery cut-off date is October 6, 2008. WHEREAS, Due to the trial schedule of Defendant counsel and the large quantity of depositions still needed to be taken by both Parties, an extension in the Discovery Cut-off date is requested and stipulated to. WHEREAS, Plaintiff counsel and Defense counsel, after meeting and conferring, have agreed to the following, IT IS HEREBY STIPULATED and agreed to below: · That the Discovery Cut-Off date be extended to December 1, 2008.

IT IS SO STIPULATED. Dated: September 23, 2008 Respectfully submitted, LAW OFFICE OF JAMES M. BARRETT /S/ James M. Barrett Attorneys for Plaintiff FRANK PALLADINI, dba LITTLE FRANKS BAR AND GRILL Dated: September 23, 2008 Respectfully submitted, MEYERS, NAVE, RIBACK, SILVER & WILSON By __________/S/_____________________________ Tricia L. Hynes Counsel for DEFENDANTS CITY OF MILPITAS, THOMAS NISHISAKI, CHARLES LAWSON, By:

Stip & Order to Extend Discovery

Case No. C06-00779 JW

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October 14,

ERIC EMMANUELLE, JOHN BUCHANOK, HENRY KWONG, KEVIN MOSQUZA, DAVID MORRIS, RAJ MAHARAJ, MARK DOYLE, and PHEAK KOR

IT IS SO ORDERED . This extension does not modify any other deadlines or hearings previously set by the Court.

______________________________________________________

HONORABLE JAMES WARE U. S. DISTRICT COURT, NORTHERN DISTRICT

Stip & Order to Extend Discovery

Case No. C06-00779 JW

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Stip & Order re: Discovery Cut-off Extended JW (HRL)

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Case No. C06-00779