Opinion
CASE NO. C-03-02930 EJD
11-30-2011
EDDIE VARGAS, SR., Petitioner, v. MIKE KNOWLES, Warden, Respondent.
Respectfully submitted, CAREY & CAREY JERRY Y. FONG, Attorney for Petitioner EDDIE VARGAS, SR. Respectfully submitted, THE ATTORNEY GENERAL'S OFFICE FOR THE STATE OF CALIFORNIA GREGORY A. OTT, Attorney for Respondent MIKE KNOWLES
JERRY Y. FONG, ESQ. (SBN 99673)
CAREY & CAREY
Attorneys for Petitioner EDDIE VARGAS, SR.
STIPULATION OF THE PARTIES TO
REQUEST ORDER EXTENDING TIME
TO FILE JOINT STATEMENT RE
STATUS OF THE CASE &
[PROPOSED] ORDER RE SAME.
Petitioner Eddie Vargas and Respondent Mike Knowles, through their respective attorneys of record, hereby submit this joint stipulation to request that the Court grant an extension of time for the parties to work together to file a joint statement regarding the status of this case.
The attorneys of the parties have been in communication over the Court's order for a joint statement (to be filed on November 30, 2011), and the parties have exchanged ideas, including legal positions regarding the procedural posture of this matter. The parties jointly believe that an additional 45 days or so will be helpful to allow the parties to work on the joint statement and to attempt to identify and resolve, if possible, certain issues relating to the status of the case.
Accordingly, the parties respectfully and jointly request that the Court extend the time to file the joint statement re status, from November 30, 2011 to January 18, 2012.
Respectfully submitted,
CAREY & CAREY
JERRY Y. FONG, Attorney for
Petitioner EDDIE VARGAS, SR.
Respectfully submitted,
THE ATTORNEY GENERAL'S OFFICE
FOR THE STATE OF CALIFORNIA
GREGORY A. OTT, Attorney for
Respondent MIKE KNOWLES
[PROPOSED] ORDER
Pursuant to the parties' stipulation and good cause appearing herein, it is hereby ordered that the joint request to extend the time to file the joint status statement shall be granted, and the parties shall file their joint status statement by January 18, 2012. It is so ordered.
__________________
JUDGE OF THE UNITED STATES
DISTRICT COURT