Ibarra v. City of Watsonville et al

Filing 25

STIPULATION AND ORDER Continuing 12/14/2012 Case Management Conference and Related Dates. Joint Case Management Statement due by 3/1/2013. Case Management Conference set for 3/8/2013 10:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J . Davila. Motions terminated: 24 STIPULATION WITH PROPOSED ORDER STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE filed by City of Watsonville, Terence Medina, Manny Solano, Carlos Palacios., ***Deadlines terminated. [24 ] STIPULATION WITH PROPOSED ORDER STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE filed by City of Watsonville, Terence Medina, Manny Solano, Carlos Palacios. Signed by Judge Edward J. Davila on 12/4/2012. (ecg, COURT STAFF) (Filed on 12/4/2012)

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Suzanne Solomon, Bar No. 169005
[e-mail]
LIEBERT CASSIDY WHITMORE
A Professional Law Corporation
153 Townsend Street, Suite 520
San Francisco, CA 94107
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
CITY OF WATSONVILLE

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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 – ECF PROGRAM
FRANCISCO IBARRA,

A Professional Law Corporation
153 Townsend Street, Suite 520
San Francisco, CA 94107

LIEBERT CASSIDY WHITMORE

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Case No. 5:12-cv-02271-EJD

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Plaintiff,
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v.

STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE
AND RELATED DATES

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CITY OF WATSONVILLE; CARLOS
PALACIOS, individually and as City
Manager; MANNY SOLANO, individually
and as Asst. Chief and/or Chief of Police;
TERENCE MEDINA, individually and as
former Chief of Police; BELCHER, EHLE,
MEDINA and ASSOCIATES; TWENTY
UNKNOWN CITY AND OTHER
EMPLOYEES,

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Defendants.
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WHEREAS, the Court approved (with modification) the parties’ stipulation to (1)
continue the Initial Case Management Conference to December 14, 2012 and (2) the Court set a
December 1, 2012 deadline for the parties to meet and confer regarding initial disclosures and a
discovery plan and (3) Case Management Conference Statements are due December 7, 2012;
WHEREAS, Defendants City of Watsonville, Carlos Palacios, Manny Solano, and Terry
Medina filed a Motion to Dismiss Plaintiff’s First Amended Complaint on October 26, 2012, and
received a hearing date of February 8, 2013, the first date available from the Court;
WHEREAS, Defendant Belcher, Ehle, Medina and Associates filed a Motion to Dismiss

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212072.1 WA100-018

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DATES
5:12-cv-02271-EJD

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Plaintiff’s First Amended Complaint on November 9, 2012, and that motion is also set for hearing

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on February 8, 2013;

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WHEREAS, the current Case Management Conference date and resulting deadlines

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flowing from that schedule would have the effect of requiring the parties to meet and confer

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before the pleadings are settled and while all Defendants have filed Motions to Dismiss that

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attack all causes of action in the First Amended Complaint;

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IT IS HEREBY STIPULATED, pursuant to Local Rule 6-2 and the accompanying

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Declaration of Suzanne Solomon, between Plaintiff Francisco Ibarra and Defendants City of

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Watsonville, Carlos Palacios, Manny Solano, Terry Medina and Belcher, Ehle, Medina and

A Professional Law Corporation
153 Townsend Street, Suite 520
San Francisco, CA 94107

LIEBERT CASSIDY WHITMORE

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Associates that the initial Case Management Conference be continued to March 8, 2013, and that

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the dates flowing from that conference be continued as follows:

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2/15/2013

discovery plan

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3/1/2013

Deadline to file Rule 26(f) report, complete initial
disclosures and file Case Management Conference statement.

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Deadline to meet and confer re initial disclosures, ADR and

IT IS SO STIPULATED.

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Dated: December , 2012

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AARON LODGE

By: ___________/S/________________
Aaron Lodge
Attorney for Plaintiff FRANCISCO IBARRA

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Dated: December , 2012

LIEBERT CASSIDY WHITMORE

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By: __________/S/_________________
Suzanne Solomon
Attorneys for Defendant
CITY OF WATSONVILLE, CARLOS
PALACIOS, MANNY SOLANO, TERRY
MEDINA

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212072.1 WA100-018

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STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DATES
5:12-cv-02271-EJD

December 4, 2012