(PC) Doe v. State of California, et al.
Filing
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ORDER on Stipulated Motion to Stay Case Pending Settlement Discussions; and ORDER signed by Magistrate Judge Barbara A. McAuliffe on 1/28/2025. All pending deadlines are VACATED, including the Scheduling Conference currently set for February 20, 2025. Case stayed. (Deputy Clerk JPX)
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ROB BONTA, State Bar No. 202668
Attorney General of California
ALICIA A. BOWER, State Bar No. 287799
Supervising Deputy Attorney General
JENNIFER BURNS, State Bar No. 312364
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: (916) 210-6393
Fax: (916) 324-5205
E-mail: Jennifer.Burns@doj.ca.gov
Attorneys for Defendants
California Department of Corrections and
Rehabilitation, State of California, and J.
Solorio
GLENN AGRE BERGMAN & FUENTES LLP
LYN R. AGRE (CASBN 178218)
BURKE STRUNSKY (CASBN 203582)
580 California Street, Suite 1420
San Francisco, CA 94104
Telephone: (415) 599-0880
lagre@glenagre.com
bstrunsky@glenagre.com
Attorneys for Plaintiff
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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FRESNO DIVISION
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NICOLE DOE,
1:24-cv-01382-JLT-BAM
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Plaintiff, STIPULATED MOTION TO STAY CASE
PENDING SETTLEMENT
DISCUSSIONS; AND
v.
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[PROPOSED] ORDER
STATE OF CALIFORNIA, et al.,
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Judge:
Hon. Barbara A. McAuliffe
Defendants. Trial Date:
Not Set
Action Filed: November 12, 2024
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Plaintiff Nicole Doe and Defendants State of California, the California Department of
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Corrections and Rehabilitation, and J. Solorio (the parties), by and through their attorneys,1
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stipulate and jointly move this Court for an order staying this case and vacating pending deadlines
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and hearings pending completion of settlement discussions in this case. Good cause supports the
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motion as follows.
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Defendant Rodriguez has not been served and has not appeared in this action. The
Office of the California Attorney General does not currently represent and does not anticipate
representing Rodriguez.
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Stipulated Mot. Stay Case Pending Settlement Discussions & [Proposed] Order (1:24-cv-01382-JLT-BAM)
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The parties have conferred regarding early settlement and have agreed to pursue early
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settlement of this action informally. Should informal settlement discussions stall, the parties
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agree to pursue either a settlement conference with the Court or private mediation. Plaintiff
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intends to make an initial settlement demand within the next two weeks. The parties anticipate
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that settlement will resolve this matter in its entirety. To allow the parties to devote time to
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preparing for settlement, the parties have agreed that proceedings and discovery in this matter
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should be stayed and any pending deadlines or hearings vacated.
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Accordingly, the parties jointly request that this matter be stayed and all pending deadlines
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and hearings be vacated, including the initial scheduling conference currently set for February 20,
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2025, pending the completion of settlement discussions. The parties will prepare and file a joint
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status report regarding settlement discussions within 90 days of entry of the stay.
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Dated: January 21, 2025
Respectfully submitted,
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GLENN, AGRE, BERGMAN, & FUENTES LLP
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/s/ Lyn R. Agre
LYN R. AGRE
Attorneys for Plaintiff
Nicole Doe
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Dated: January 21, 2025
Respectfully submitted,
ROB BONTA
Attorney General of California
ALICIA A. BOWER
Supervising Deputy Attorney General
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JENNIFER BURNS
Deputy Attorney General
Attorneys for Defendants
California Department of Corrections and
Rehabilitation, State of California, and J.
Solorio
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Stipulated Mot. Stay Case Pending Settlement Discussions & [Proposed] Order (1:24-cv-01382-JLT-BAM)
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ORDER
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Having considered the parties’ stipulation, and good cause appearing, it is HEREBY
ORDERED as follows:
1. The motion to stay this case pending settlement discussions (ECF No. 9) is
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GRANTED.
2. This action is STAYED, including all discovery, pending completion of settlement
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discussions.
3. All pending deadlines are VACATED, including the Scheduling Conference currently
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set for February 20, 2025.
4. The parties SHALL prepare and file a joint status report regarding settlement
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discussions within ninety (90) days following entry of this Order.
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IT IS SO ORDERED.
Dated:
/s/ Barbara A. McAuliffe
January 28, 2025
_
UNITED STATES MAGISTRATE JUDGE
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Stipulated Mot. Stay Case Pending Settlement Discussions & [Proposed] Order (1:24-cv-01382-JLT-BAM)
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