Coleman, et al v. Schwarzenegger, et al

Filing 8196

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 04/11/2024 EXTENDING the deadline to file a Joint Motion and Stipulation required by 8181 Order, until 04/25/2024. (Nair, C) Modified on 4/12/2024 (Nair, C).

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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
DISABILITY RIGHTS EDUCATION
AND DEFENSE FUND, INC.
Ed Roberts Campus
3075 Adeline Street, Suite 210
Berkeley, California 94703-2578
Telephone: [phone]

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11 Attorneys for Plaintiffs

MICHAEL W. BIEN – 096891
ERNEST GALVAN – 196065
LISA ELLS – 243657
JENNY S. YELIN – 273601
THOMAS NOLAN – 169692
MICHAEL S. NUNEZ – 280535
MARC J. SHINN-KRANTZ – 312968
ALEXANDER GOURSE – 321631
ADRIENNE PON HARROLD – 326640
AMY XU – 330707
ADRIENNE SPIEGEL – 330482
BENJAMIN W. HOLSTON – 341439
MAYA E. CAMPBELL – 345180
LUMA KHABBAZ – 351492
JARED MILLER – 353641
ROSEN BIEN
GALVAN & GRUNFELD LLP
101 Mission Street, Sixth Floor
San Francisco, California 94105-1738
Telephone: [phone]

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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16 RALPH COLEMAN, et al.,

Case No. 2:90-CV-00520-KJM-DB

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STIPULATION AND ORDER
EXTENDING TIME FOR JOINT
MOTION AND STIPULATION PER
ECF NO. 8181

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Plaintiffs,
v.

19 GAVIN NEWSOM, et al.,
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Defendants.

Judge: Hon. Kimberly J. Mueller

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[4466659.2] 20594924.1

STIP. AND ORDER EXTENDING TIME FOR JOINT MOTION AND STIP. PER ECF NO. 8181

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On April 2, 2024, the Court ordered the parties to file a joint motion to clarify the

2 Court’s February 7, 2022, ECF No. 7456, as to “defendants’ obligation to inform the court
3 to the extent [the new RHU] regulations may replace certain chapters of the Program
4 Guide, a primary remedial plan in this action,” accompanied by a stipulation regarding the
5 substantive portions of the RHU regulations and a recitation of the Special Master’s
6 position. ECF No. 8181 at 6.
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While the parties have identified significant areas of agreement in the negotiations

8 to date, they have not exhausted their meet and confer process regarding the substantive
9 provisions of Defendants’ new RHU initiative, which includes the RHU regulations and a
10 RHU mental health policy. The parties wish to continue meeting and conferring to see
11 whether they can come to agreement about the few remaining areas of dispute regarding
12 the RHU initiative, which remain pending after their prior negotiations, and to discuss their
13 respective positions regarding the impact of the February 7, 2022 Order on Defendants’
14 obligations to move forward with the regulations and policy.
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Unfortunately, the parties will not be able to complete this meet and confer process

16 in time to present the joint motion by April 15, 2024, as ordered. ECF No. 8181 at 7. The
17 three members of Plaintiffs’ team who are responsible for the joint motion are each on pre18 planned vacations for part or all of the week of April 8-12, 2024, and the member of
19 Plaintiffs’ team who has led the months-long negotiations regarding the RHU initiative is
20 also unavailable that week due to an Armstrong v. Newsom monitoring tour. While
21 Plaintiffs proposed meeting on April 3, 4, or 5, defense counsel were not available on those
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[4466659.2] 20594924.1

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STIP. AND ORDER EXTENDING TIME FOR JOINT MOTION AND STIP. PER ECF NO. 8181

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The parties therefore respectfully request a ten-day extension of time until April 25,

2 2024 to complete the negotiations, and to prepare and file the joint motion and stipulation.
3 The parties recognize and appreciate the Court’s goal of resolving the joint motion “before
4 the end of April 2024,” ECF No. 8181 at 6, but believe they can narrow the dispute and
5 present a more cogent motion if they can first exhaust the meet and confer process.
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7 DATED: April 5, 2024

ROSEN BIEN GALVAN & GRUNFELD LLP

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By: /s/ Jenny S. Yelin
Jenny S. Yelin

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Attorneys for Plaintiffs

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DATED: April 5, 2024

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HANSON BRIDGETT LLP
By: /s/ Paul Mello
Paul Mello

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Attorneys for Defendants

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18 DATED: April 5, 2024
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ROB BONTA, ATTORNEY GENERAL OF
CALIFORNIA

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By: /s/ Elise Thorn
Elise Thorn

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Attorneys for Defendants

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[4466659.2] 20594924.1

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STIP. AND ORDER EXTENDING TIME FOR JOINT MOTION AND STIP. PER ECF NO. 8181

ORDER

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The parties are granted an extension to April 25, 2024 to file the joint motion and

4 stipulation that is required by the Court’s April 2, 2024 Order, ECF No. 8181.
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IT IS SO ORDERED.

6 DATED: April 11, 2024.
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[4466659.2] 20594924.1

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STIP. AND ORDER EXTENDING TIME FOR JOINT MOTION AND STIP. PER ECF NO. 8181