Verdugo v. City Of San Jose et al

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC 	Case Number: 5:25-cv-08776-SVK
GEORGE VERDUGO
2984 Almond Drive
San Jose, CA 95148
Telephone: (408) 401-5636
Email: georgeverdugo@gmail.com
Plaintiff, Pro Se
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
GEORGE VERDUGO,
Plaintiff,
v.
CITY OF SAN JOSE, OFFICER ROCHA
#5077, and OFFICER LEGLU, et al., and
DOES 1–10, inclusive,
Defendants.
Case Number: 5:25-cv-08776-SVK
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE;
DECLARATION OF GEORGE
VERDUGO (CIVIL L.R. 6-2)
Judge: Hon. Susan van Keulen
Plaintiff George Verdugo, appearing pro se, and Defendants City of San José, Officer
Rocha, and Officer Leglu, through their counsel of record (together, the "Parties"), stipulate as
follows:
1. 	On July 22, 2026, the Clerk set the Initial Case Management Conference for October
13, 2026, at 9:30 a.m. (Dkt. 36.)
2. 	On October 2, 2026, the Clerk continued the Initial Case Management Conference to
October 15, 2026, at 9:30 a.m.
3. 	Defendants filed their Case Management Statement on October 6, 2026 (Dkt. 39).
Plaintiff filed his Case Management Statement on October 7, 2026 (Dkt. 41).
Case 5:25-cv-08776-SVK Document 43 Filed 10/13/26 Page 1 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC 	Case Number: 5:25-cv-08776-SVK
4. 	The Parties held their Rule 26(f) conference on October 8, 2026, and agreed to
exchange initial disclosures by October 22, 2026.
5. 	Plaintiff made travel arrangements in reliance on the October 13, 2026 date and is
unavailable October 14–17, 2026. Counsel for Defendants will be out of the country during the
week of the October 15, 2026 conference but arranged for coverage of the hearing.
6. 	On October 8, 2026, Plaintiff requested a continuance by email to the Courtroom
Deputy, and Defendants do not oppose that request. The Courtroom Deputy directed the Plaintiff to
file a stipulation and proposed order.
7. 	This request, made for the reasons stated above, is the Plaintiff’s first request to
continue the Initial Case Management Conference. It is made in good faith and not for purposes of
delay, and it does not affect any other date in this case.
THEREFORE, the Defendants do not oppose and therefore stipulate to a brief continuance
subject to the Court's approval. The Initial Case Management Conference currently set for October
15, 2026, be continued to a date on or after October 28, 2026 that is convenient for the Court, other
than October 22 or October 27, 2026, and that the Parties may file updated case management
statements no later than seven days before the continued conference.
IT IS SO STIPULATED.
Dated: October 9, 2026
/s/ George Verdugo
George Verdugo
Plaintiff, Pro Se
Dated: October 9, 2026
_/s/Brian Loftus_________________
Brian J. Loftus
Chief Deputy City Attorney
Attorneys for Defendants
Case 5:25-cv-08776-SVK Document 43 Filed 10/13/26 Page 2 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC 	Case Number: 5:25-cv-08776-SVK
DECLARATION OF GEORGE VERDUGO PURSUANT TO CIVIL L.R. 6-2(a)
I, George Verdugo, declare:
1. 	I am the plaintiff in this action, appearing pro se. I have personal knowledge of the
facts in this declaration and could testify competently to them.
2. 	Reasons for the request. The Initial Case Management Conference was originally set
for October 13, 2026 (Dkt. 36), and I made travel arrangements in reliance on that date. On October
2, 2026, the conference was continued to October 15, 2026. I will be traveling and am unavailable
October 14–17, 2026. Counsel for Defendants has informed me that he will be out of the country
that week and arranged for coverage by another attorney in his office. I am also unavailable on
October 22, 2026. In addition, I am unavailable on October 27, 2026, because of a previously
scheduled hearing in another court.
3. 	Previous time modifications. To my knowledge, the previous time modifications in
this case are: (a) the Clerk's November 24, 2025 notice vacating the December 23, 2025 motion
hearing (Dkt. 19); (b) the Court's December 9, 2025 order extending Defendants' reply deadline to
December 15, 2025 (Dkt. 22); (c) the Clerk's December 15, 2025 notice vacating the January 13,
2026 Case Management Conference (Dkt. 23); (d) the Clerk's June 3, 2026 notice vacating the June
16, 2026 motion hearing (Dkt. 32); (e) the Clerk's October 2, 2026 notice continuing the Initial Case
Management Conference to October 15, 2026; and (f) the Court's October 7, 2026 order (Dkt. 40)
directing Plaintiff to file his Case Management Statement by October 9, 2026.
4. 	Effect on the schedule. No case schedule has yet been set. The requested continuance
would move only the Initial Case Management Conference and would not affect the Parties' agreed
October 22, 2026 exchange of initial disclosures.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on October 9, 2026, at San Jose, California.
/s/ George Verdugo
George Verdugo
Case 5:25-cv-08776-SVK Document 43 Filed 10/13/26 Page 3 of 4

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC 	Case Number: 5:25-cv-08776-SVK
[PROPOSED] ORDER
Pursuant to the Parties' stipulation, and good cause appearing, the Initial Case Management
Conference set for October 15, 2026, is CONTINUED to November 10, 2026, at 9:30 a.m., via
Zoom webinar. The Parties may file updated case management statements no later than seven days
before the continued conference.
IT IS SO ORDERED.
Dated: October 13, 2026
_______________________________
HON. SUSAN VAN KEULEN
United States Magistrate Judge
Case 5:25-cv-08776-SVK Document 43 Filed 10/13/26 Page 4 of 4