Greater Stockton Chamber of Commerce, et al v. Kelso, et al

Filing 46

ORDER signed by Senior Judge Lawrence K. Karlton on 4/27/10: All litigation deadlines are continued by thirty (30) days. (Kaminski, H)

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FUTTERMAN DUPREE DODD CROLEY MAIER LLP MARTIN H. DODD (SBN 104363) JAIME G. TOUCHSTONE (SBN 233187) 180 Sansome Street, 17th Floor San Francisco, California 94104 Telephone: [phone] Facsimile: [phone] mdoddfddcm.com [e-mail] McDONOUGH HOLLAND & ALLEN PC Attorneys at Law HARRIET A. STEINER (SBN 109436) KIMBERLY E. HOOD (SBN 229195) 500 Capitol Mall, 18th Floor Sacramento, California 95814 Telephone: [phone] Facsimile: 916.444.8334 [e-mail] [e-mail] RECEIVER'S OFFICE OF LEGAL AFFAIRS EVELYN M. MATTEUCCI (SBN 78859) Chief Counsel, Construction Office of the Receiver California Prison Health Care Services 501 J Street, Suite 100 Sacramento, California 95814 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Respondents J. Clark Kelso, Receiver, and California Prison Healthcare Receivership Corp. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION GREATER STOCKTON CHAMBER OF COMMERCE, et al., ) ) ) Petitioners, ) ) v. ) ) J. CLARK KELSO, in his capacity as Receiver, ) et al., ) ) Respondents. ) ) 1 Case No. 2:09-cv-03308-LKK-JFM NOTICE OF TENTATIVE SETTLEMENT AND REQUEST FOR EXTENSION OF TIME; ORDER THEREON

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1310356v1 36363/0015

Ntc of Tent Stlmt & Req for Ext of Time Case No. 2:09-cv-03308-LKK-JFM

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NOTICE IS HEREBY GIVEN the parties have reached a tentative settlement agreement in the above captioned case. The parties believe they have reached agreement in principle on the material settlement deal terms (subject to obtaining governmental approvals), and are in the process of preparing an integrated global settlement agreement memorializing those agreed terms which they anticipate will be finalized and executed by the authorized representatives of all parties within the next three weeks, allowing the case to be dismissed in its entirety. Given this status, and the parties' desire to facilitate the settlement process and to avoid unnecessary expense litigating the case, the parties request that the Court continue all litigation deadlines by thirty (30) days. DATED: April 26, 2010. McDONOUGH HOLLAND & ALLEN PC Attorneys at Law

By:

/s/ Harriet A. Steiner HARRIET A. STEINER

Attorneys for Respondents J. Clark Kelso, Receiver, and California Prison Healthcare Receivership Corp. DATED: April 26, 2010. FUTTERMAN DUPREE DODD CROLEY MAIER LLP

By:

/s/ Martin H. Dodd MARTIN H. DODD

Attorneys for Respondents J. Clark Kelso, Receiver, and California Prison Healthcare Receivership Corp.

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1310356v1 36363/0015

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DATED: April 26, 2010. RECEIVER'S OFFICE OF LEGAL AFFAIRS

By:

/s/ Evelyn M. Matteucci EVELYN M. MATTEUCCI

Attorneys for Respondents J. Clark Kelso, Receiver, and California Prison Healthcare Receivership Corp. DATED: April 26, 2010. MILLER STARR REGALIA

By:

/s/ Arthur F. Coon ARTHUR F. COON

Attorneys for Respondent California Department of Corrections and Rehabilitation DATED: April 26, 2010. HERUM CRABTREE

By:

/s/ Steven A. Herum STEVEN A. HERUM

Attorneys for Petitioners Greater Stockton Chamber of Commerce, County of San Joaquin, and City of Stockton DATED: April 26, 2010. OFFICE OF THE SAN JOAQUIN COUNTY COUNSEL

By:

/s/ J. Mark Myles J. MARK MYLES

Attorneys for Petitioner County of San Joaquin

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Ntc of Tent Stlmt & Req for Ext of Time Case No. 2:09-cv-03308-LKK-JFM

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DATED: April 26, 2010. OFFICE OF THE STOCKTON CITY ATTORNEY

By:

/s/ Guy Petzold GUY PETZOLD

Attorneys for Petitioner City of Stockton IT IS SO ORDERED. DATED: April 27, 2010

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Ntc of Tent Stlmt & Req for Ext of Time Case No. 2:09-cv-03308-LKK-JFM