Bardina et al v. UNITED STATES OF AMERICA

Filing 30

STIPULATION AND ORDER Granting Request To Extend Deadline To Stipulate To ADR Process re 29 Stipulation. The deadline to file a stipulated request to an ADR process be extended to January 26, 2012. Signed by Judge Edward J. Davila on 11/17/2011. (ecg, COURT STAFF) (Filed on 11/17/2011)

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MELINDA HAAG (CABN 132612)
United States Attorney
THOMAS MOORE (ASBN 4305-O78T)
Assistant United States Attorney
Chief, Tax Division
CYNTHIA STIER (DCBN 423256)
Assistant United States Attorney
9th Floor Federal Building
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
Telephone: [phone]

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Attorneys for the United States of America

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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JUAN BARDINA and PATRICIA
BARDINA,

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Plaintiffs,
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v.
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UNITED STATES OF AMERICA,
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Defendant.
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____________________________________)

Case No. C-10-03454-EJD
STIPULATED REQUEST TO
EXTEND DEADLINE TO STIPULATE
TO ADR PROCESS AND [PROPOSED]
ORDER

The parties, Plaintiffs, Juan Bardina and Patricia Bardina, and Defendant, United States of
America, hereby stipulate and request, subject to the Court’s approval, as follows:
1. This Court extended the discovery deadline to allow the government to take the

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deposition of Plaintiff Juan Bardina. The deposition was taken on November 10, 2011. Plaintiff

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agreed to provide documents to the United States following the deposition which may be

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instrumental in settlement negotiations.

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2. The Court ordered the parties to file a stipulation for an ADR process within ten days
following the deposition. (Order, Docket No. 28)
3. The parties would like the opportunity to allow Plaintiff to provide the requested

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documents to the United States and an opportunity to thereafter determine whether a settlement

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between the parties can be reached.

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4. The parties request that this Court allow the parties until January 26, 2012, to file a
stipulated request for an ADR process.

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MELINDA HAAG
United States Attorney

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Dated: 11/15/11

:

/s/ Cynthia Stier
CYNTHIA STIER
Assistant U.S. Attorney
Attorneys for the United States of America

Dated: 11/15/11

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:

/s/ David Kirsch
DAVID KIRSCH
Ten Almaden Blvd., Suite 1250
San Jose, CA 95113-2233
[phone]
Attorney for Juan and Patricia Bardina

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ORDER
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Pursuant to the Stipulation filed by the parties, it is HEREBY ORDERED that the deadline to

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file a stipulated request to an ADR process be extended to January 26, 2012. It is FURTHER

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ORDERED as follows:

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Dated: November 17, 2011

_____________________
EDWARD J. DAVILA
United States District Judge