Coleman, et al v. Schwarzenegger, et al

Filing 6677

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 5/18/20 GRANTING the parties an extension until May 20, 2020 to file the stipulation identifying Program Guide departures. (Kaminski, H)

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XAVIER BECERRA
Attorney General of California
MONICA N. ANDERSON
Senior Assistant Attorney General
ADRIANO HRVATIN
Supervising Deputy Attorney General
KYLE A. LEWIS, State Bar No. 201041
ELISE OWENS THORN, State Bar No. 145931
TYLER V. HEATH, State Bar No. 271478
Deputy Attorneys General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants

ROMAN M. SILBERFELD, State Bar No. 62783
GLENN A. DANAS, State Bar No. 270317
ROBINS KAPLAN LLP
2049 Century Park East, Suite 3400
Los Angeles, CA 90067-3208
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Special Counsel for Defendants

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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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Case No. 2:90-cv-00520 KJM-DB (PC)

RALPH COLEMAN, et al.,

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v.

Plaintiffs, STIPULATION AND ORDER TO
EXTEND TIME TO FILE STIPULATION
IDENTIFYING PROGRAM GUIDE
DEPARTURES

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GAVIN NEWSOM, et al.,
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Defendants.
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On April 17, 2020, the Court ordered the parties to file by May 1, 2020 a stipulation

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identifying the “temporary departures from certain Program Guide requirements” for the

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provision of mental health care that Defendants had implemented in response to the COVID-19

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pandemic. (ECF No. 6622 at 2-3.) The parties met and conferred in response to the Court’s April

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17 order, and determined more time would be necessary to come to agreement on the content of

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the stipulation. (ECF No. 6652 at 2.) Accordingly, the parties requested and the Court granted

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the parties an extension until May 15, 2020 to file the stipulation. (Id. at 2, 3.)

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[3545068.2]

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Stip. & Order Extend Time File Stip. Re: Program Guide Departures (2:90-cv-00520 KJM-DB (PC))

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Since the initial meet and confer, the parties have continued to negotiate, under the Special

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Master’s supervision, the content of the Court-ordered stipulation identifying COVID-19-based

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departures from Program Guide requirements for mental health treatment and programming.

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During this period, the parties have exchanged draft stipulations and discussed various provisions,

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with the mutual goal of reaching a stipulation concerning this issue. Twice during the afternoon

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of May 15, Defendants sent Plaintiffs a version of the draft stipulation, but for reasons unknown

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to the parties, Plaintiffs did not receive that correspondence. The parties discovered this technical

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issue after the close of business today and continued their negotiations on the limited remaining

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points, but both sides determined that additional time is needed to reach an agreement.

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The parties believe that, with a short extension of time, they will complete negotiations and

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reach a stipulation identifying the temporary departures from certain Program Guide requirements

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for the provision of mental health care that Defendants had implemented in response to the

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COVID-19 pandemic. Accordingly, the parties request an extension of three business days from

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the present due date, such that their stipulation would be due by Wednesday, May 20, 2020.

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The Special Master is aware of and approves this stipulated request for additional time.

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[3545068.2]

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Stip. & Order Extend Time File Stip. Re: Program Guide Departures (2:90-cv-00520 KJM-DB (PC))

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Dated: May 15, 2020

XAVIER BECERRA
Attorney General of California
ADRIANO HRVATIN
Supervising Deputy Attorney General

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/s/ Kyle A. Lewis

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Kyle A. Lewis
Deputy Attorney General
Attorneys for Defendants

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Dated: May 15, 2020

ROSEN BIEN GALVAN & GRUNFELD LLP

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/s/ Lisa Ells

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Lisa Ells
Attorneys for Plaintiffs

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IT IS SO ORDERED.
DATED: May 18, 2020.

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[3545068.2]

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Stip. & Order Extend Time File Stip. Re: Program Guide Departures (2:90-cv-00520 KJM-DB (PC))