Campbell et al v. City of Oakland et al

Filing 64

STIPULATION AND ORDER RE 63 FOR AN ORDER EXTENDING DATE FOR AMENDMENT OF PLEADINGS. Signed by Judge Richard Seeborg on 6/11/12. (cl, COURT STAFF) (Filed on 6/11/2012)

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1 2 3 4 5 6 Alan L. Schlosser (#49957) Michael T. Risher (#191627) Linda Lye (#215584) ACLU Foundation of Northern California 39 Drumm Street San Francisco, CA 94111 (415) 621-2493; (415) 255-1478 aschlosser@aclunc.org, mrisher@aclunc.org, llye@aclunc.org Attorneys for Plaintiffs Kerie Campbell, Marcus Kryshka, and ACLU-NC 7 8 9 10 RACHEL LEDERMAN, SBN 130192 Rachel Lederman & Alexsis C. Beach, Attorneys at Law 558 Capp Street San Francisco, CA 94110 (415) 282-9300; fax (415) 285-5066 rlederman@2momslaw.com 11 and additional counsel listed on pleadings 12 13 Attorneys for plaintiffs Timothy Scott Campbell et al. 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 18 TIMOTHY SCOTT CAMPBELL, et al., 19 Plaintiffs, 20 vs. 21 22 CITY OF OAKLAND, et al. No. CV11-05498 RS STIPULATED REQUEST FOR AN ORDER EXTENDING DATE FOR AMENDMENT OF PLEADINGS, DECLARATION AND PROPOSED ORDER Complaint Filed: Nov. 14, 2011 Trial Date: May 28, 2013 Defendants. 23 24 25 26 27 28 Whereas, this court set a deadline of June 30, 2012, for the parties to complete all amendments to the pleadings; STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS 1 1 Whereas all current parties agree that it would be most efficient to join all parties 2 in one action, and additional time is needed to do so as more fully set forth in the attached 3 declaration of plaintiffs’ counsel; 4 5 6 7 THEREFORE, the parties through their respective counsel jointly request that the court extend the date for amendment of pleadings to August 1, 2012. It is so stipulated. Dated: June 8, 2012 8 /S/ Rachel Lederman Attorneys for plaintiffs Scott Campbell, et al. 9 /S/ 10 11 Linda Lye Attorneys for plaintiffs ACLU-NC, et al. 12 /S/ 13 William Simmons, Supervising City Attorney Attorney for defendants 14 15 SIGNATURE ATTESTATION 16 I am the ECF User whose ID and Password are being used to file 17 this stipulated request. In compliance with General Order 45, X.B., I hereby attest that 18 Ms. Lye and Mr. Simmons have concurred in this filing. 19 20 Dated: June 8, 2012 /S/ Rachel Lederman 21 22 23 24 25 26 27 28 STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS 2 1 2 3 4 DECLARATION OF RACHEL LEDERMAN I am an attorney admitted to practice before this court and the attorney of record for plaintiffs Timothy Scott Campbell, Mark McKinnie, and Michael Siegel. As discussed at the Case Management Conference, plaintiffs’ counsel represent 5 approximately fifteen people who were injured during the two demonstrations at issue in 6 this case. Because this matter was originally filed only two weeks after these events, in 7 conjunction with an application for a Temporary Restraining Order, all plaintiffs and 8 defendants were not named at that time. Each of the two events at issue involved a 9 mutual aid operation by a large number of law enforcement agencies. Counsel have been 10 working diligently to investigate and obtain discovery in order to ascertain the responsible 11 parties and avoid unnecessarily naming government entity or individual defendants who 12 do not bear responsibility. Due to the large volume of evidence involved, additional time 13 is required to complete this process and prepare the amended pleadings. 14 15 I declare under penalty of perjury that the foregoing is true and correct. Executed this June 8, 2012, at San Francisco, California. 16 17 /S/ Rachel Lederman 18 19 20 21 22 23 24 25 26 27 28 STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS 3 1 2 3 [PROPOSED] ORDER Pursuant to stipulation, the court sets the following deadline for completion of amendment of pleadings: August 1, 2012. 4 5 6 7 6/11/12 Dated: _________________ ____________________________ RICHARD SEEBORG United States District Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS 4