Millar et al v. City of Sunnyvale et al

Filing 52

STIPULATION AND ORDER Granting Extension of Time for Filing Date Joint Case Management Statement re 51 Stipulation. Joint Case Management Conference statement due 5/13/2011. Signed by Judge Edward J. Davila on 5/11/2011. (ecg, COURT STAFF) (Filed on 5/11/2011)

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Gregory M. Fox, State Bar No. 070876
Arlene C. Helfrich, State Bar No. 096461
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants CITY OF SUNNYVALE, DEVON KLEIN,
CARL RUSHMEYER and KELLY FITZGERALD

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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)
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Plaintiffs,
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vs.
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CITY OF SUNNYVALE, DEVON KLEIN,
CARL RUSHMEYER, KELLY FITZGERALD, )
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and DOES 1 to 20,
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Defendants.
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BRUCE MILLAR, PATRICIA MILLAR, and
DAVID MILLAR,

Case No.: CV10-0827 EJD
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE FILING DATE FOR JOINT
CASE MANAGEMENT

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The parties, acting by and through their respective legal counsel, herein stipulate for an Order

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continuing the filing date for the Joint Case Management Conference Statement presently set for

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Friday, May 6, 2011 to Friday, May 13, 2011. Good cause exists to move the Case Management

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Conference for the following reasons. The parties need additional time to complete the meet and

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confer process on the contents of the joint statement given the complexity of legal issues, the

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defendants’ pending motion to dismiss now scheduled for September 16, 2011, additional motions the

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parties may bring and whether those motions may also be scheduled for September 16, 2011 as well as

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a stipulated briefing schedule for said motions; the service status of all named defendants and whether

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the case would benefit from another ADR session.
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STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

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Dated: May 6, 2011

LAW OFFICES OF NICHOLAS DAMER

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By:

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Dated: May 6, 2011

/s/
Nicholas Damer
Attorney for Plaintiffs
BERTRAND, FOX & ELLIOT

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By:

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/s/
Gregory M. Fox
Arlene C. Helfrich
Attorney for Defendants
CITY OF SUNNYVALE, DEVON KLEIN,
CAROL RUSHMEYER and KELLY FITZGERALD

ATTORNEY ATTESTATION
I hereby attest that I have on file all holograph signatures for any signatures indicated by a
conformed signature (“/s/”) within this E-filed document.

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Dated: May 6, 2011

/s/
Gregory M. Fox

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ORDER
Good cause appearing, it is ordered that the above Stipulation is approved and the filing date
for the updated Joint Case Management Conference Statement is continued from Friday, May 6,
2011 to Friday , May 13, 2011.

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May 11, 2011
Dated: _________________________

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United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE