Coleman, et al v. Schwarzenegger, et al

Filing 6158

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 05/17/19 ORDERING that Defendants shall provide the first set of patient-level data, as described in paragraph 1 of the foregoing stipulation, to Plaintiffs and the Special Master by 05/24/19. The parties and Special Master shall meet at least monthly between June 2019 and August 2019 to discuss the data and the application of proposed exceptions to the twenty-four hour timeline to individual patients, and to finalize the proposed language for the Program Guide Addendum. The parties will submit the proposed Addendum to the Court by 08/30/19. (Benson, A.)

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DONALD SPECTER – 083925
STEVEN FAMA – 099641
MARGOT MENDELSON – 268583
PRISON LAW OFFICE
1917 Fifth Street
Berkeley, California 94710-1916
Telephone: [phone]
CLAUDIA CENTER – 158255
AMERICAN CIVIL LIBERTIES UNION
FOUNDATION OF NORTHERN
CALIFORNIA, INC.
39 Drumm Street
San Francisco, California 94111-4805
Telephone: [phone]

MICHAEL W. BIEN – 096891
JEFFREY L. BORNSTEIN – 099358
ERNEST GALVAN – 196065
THOMAS NOLAN – 169692
LISA ELLS – 243657
JENNY S. YELIN – 273601
MICHAEL S. NUNEZ – 280535
JESSICA WINTER – 294237
MARC J. SHINN-KRANTZ – 312968
CARA E. TRAPANI – 313411
ROSEN BIEN
GALVAN & GRUNFELD LLP
101 Mission Street, Sixth Floor
San Francisco, California 94105-1738
Telephone: [phone]

9 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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RALPH COLEMAN, et al.,

CASE NO. 2:90-CV-00520-KJM-DB

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Plaintiffs,
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v.
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GAVIN NEWSOM, et al.,
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STIPULATION AND ORDER
SETTING SCHEDULE FOR
FINALIZING PROPOSED
ADDENDUM FOR EXCEPTIONS TO
24-HOUR TRANSFER TIMELINE
FOR MHCB CARE

Defendants.
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Judge: Hon. Kimberly J. Mueller

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[3383220.3]

STIPULATION AND ORDER SETTING SCHEDULE FOR FINALIZING PROPOSED ADDENDUM FOR
EXCEPTIONS TO 24-HOUR TRANSFER TIMELINE FOR MHCB CARE

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The Court’s April 26, 2019 Order instructed the parties to suggest a schedule “for

2 finalizing the proposed addendum covering exceptions to the twenty-four hour timeline for
3 transfer to mental health crisis bed (MHCB) care.” ECF No. 6135 at 2. The parties have
4 met and conferred regarding a schedule and accordingly stipulate as follows:
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1.

As contemplated by the August 14, 2017 Supplemental Stipulation and

6 Order, see ECF No. 5660 at 3, Defendants shall provide “individual patient-level data” to
7 Plaintiffs and the Special Master “as part of the process for developing the addendum,” so
8 that the parties may “discuss on a monthly basis any Mental Health Crisis Bed transfer that
9 may qualify for an exception to the Program Guide timelines.” Id. at 2. Defendants agree
10 to provide the first set of patient-level data no later than May 24, 2019.
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2.

The parties and Special Master will meet at least monthly between June 2019

12 and August 2019 to discuss the data and the application of proposed exceptions to the
13 twenty-four hour timeline to individual patients, and to finalize the proposed language for
14 the Program Guide Addendum.
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3.

The parties will submit the proposed Addendum to the Court no later than

16 August 30, 2019.
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[3383220.3]

STIPULATION AND ORDER SETTING SCHEDULE FOR FINALIZING PROPOSED ADDENDUM FOR
EXCEPTIONS TO 24-HOUR TRANSFER TIMELINE FOR MHCB CARE

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4.

The Special Master has reviewed this stipulation and has no objection to the

2 proposed schedule.
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4 DATED: May 3, 2019

Respectfully submitted,

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ROSEN BIEN GALVAN & GRUNFELD LLP

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By:

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/s/ Jenny S. Yelin
Jenny S. Yelin

Attorneys for Plaintiffs

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11 DATED: May 3, 2019
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Respectfully submitted,
XAVIER BECERRA
Attorney General of California

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By:

/s/ Tyler V. Heath
Tyler V. Heath
Deputy Attorney General

Attorneys for Defendants

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[3383220.3]

STIPULATION AND ORDER SETTING SCHEDULE FOR FINALIZING PROPOSED ADDENDUM FOR
EXCEPTIONS TO 24-HOUR TRANSFER TIMELINE FOR MHCB CARE

ORDER

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It is hereby ordered that:

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1.

Defendants shall provide the first set of patient-level data, as described in

4 paragraph 1 of the foregoing stipulation, to Plaintiffs and the Special Master no later than
5 May 24, 2019.
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2.

The parties and Special Master shall meet at least monthly between June

7 2019 and August 2019 to discuss the data and the application of proposed exceptions to the
8 twenty-four hour timeline to individual patients, and to finalize the proposed language for
9 the Program Guide Addendum.
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3.

The parties will submit the proposed Addendum to the Court no later than

11 August 30, 2019.
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IT IS SO ORDERED.

13 DATED: May 17, 2019.
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UNITED STATES DISTRICT JUDGE

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[3383220.3]

STIPULATION AND ORDER SETTING SCHEDULE FOR FINALIZING PROPOSED ADDENDUM FOR
EXCEPTIONS TO 24-HOUR TRANSFER TIMELINE FOR MHCB CARE