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Jose Garcia v. City and County of San Francisco

August 28, 2012

JOSE GARCIA,
PLAINTIFF,
v.
CITY AND COUNTY OF SAN FRANCISCO, RYAN JONES, AND DOES ONE THROUGH
DEFENDANTS.



The opinion of the court was delivered by: Assigned to Hon. Saundra B. Armstrong

LAW OFFICES OF WALKUP, MELODIA, KELLY & SCHOENBERGER A PROFESSIONAL CORPORATION 650 CALIFORNIA STREET, 26TH FLOOR SAN FRANCISCO, CALIFORNIA 94108-2615 (415) 981-7210 MATTHEW D. DAVIS (State Bar #141986) ANDREW P. MCDEVITT (State Bar #271371) ATTORNEYS FOR PLAINTIFFS

PLAINTIFF AND DEFENDANT'S JOINT STIPULATION AND [PROPOSED] ORDER TO MODIFY INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES FIFTY,

Complaint Filed: March 16, 2012

This Stipulation is made by and between Plaintiff Jose Garcia and Defendants City and County of San Francisco and Ryan Jones, in reference to the following: 20 NOW, THEREFORE, the parties hereto stipulate and agree to and respectfully request the 21 below modifications and/or amendments to this Court's Order Setting Initial Case Management 22 Conference and ADR Deadlines: 23

The parties contend there is good cause for this request for the following reasons:

1. Parties would like to explore the possibility of resolving this action without further 25 litigation. The parties would like to use the next 45 days discussing resolution rather than 26 discovery. 27

2. The request for continuance is made in good faith and not for delay.

3. The parties agree to and submit the following proposed modifications to the scheduling order: 3

a. All deadlines will be postponed by at least forty-five (45) days;

b. That the deadline to file Rule 26(f) Report and file a Joint Case Management Statement per Standing Order re Contents of Joint Case Management Statement be 6 moved from August 27, 2012 to October 17, 2012; 7

c. That the Initial Case Management Conference be moved from September 5, 2012 to October 24, 2012 at 2:30 p.m.; 9 10

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. 24

Dated: August 27, 2012 /s/ Andrew P. McDevitt ANDREW P. MCDEVITT WALKUP, MELODIA, KELLY & SCHOENBERGER LAW OFFICES OF A PROFESSIONAL ...


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