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

Filing 50

ORDER signed by Senior Judge Lawrence K. Karlton on 7/20/10. The Court grants a further 45 day extension of time to provide sufficient time for the parties to execute the settlement agreement and file the appropriate court filings to fully resolve this matter. (Mena-Sanchez, L)

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

Doc. 50

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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
Request for Further Extension to Execute and Implement Settlement with Court Filings; Order Thereon 1342597v1 36363/0015 Case No. 2:09-cv-03308-LKK-JFM Dockets.Justia.com

Case No. 2:09-cv-03308-LKK-JFM REQUEST FOR FURTHER EXTENSION TO EXECUTE AND IMPLEMENT SETTLEMENT WITH COURT FILINGS; ORDER THEREON

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

NOTICE IS HEREBY GIVEN the parties have reached a settlement agreement in the above captioned case, and that the State Respondents, on Wednesday, July 14, 2010, received authorization to execute the settlement agreement. The Petitioners have also received approval to execute the settlement agreement. All parties intend to execute the settlement agreement within the next thirty (30) days based on the approvals from their respective governing bodies or approval authorities. On April 27, 2010, the Court granted a 30-day extension of all litigation deadlines to facilitate this process, which is complex and time-consuming given the nature and number of parties and issues involved.. On June 2, 2010, the Court granted a further 45-day extension to allow time to finalize and document the settlement agreement. The parties request that the Court grant a further extension of all litigation deadlines by an additional forty-five (45) days to provide sufficient time for the parties to execute the settlement agreement and file the appropriate court filings to fully resolve this matter. DATED: July 16, 2010. McDONOUGH HOLLAND & ALLEN PC Attorneys at Law By: /s/ Harriet A. Steiner HARRIET A. STEINER

DATED: July 16, 2010.

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

2
Request for Further Extension to Execute & Implement Settlement with Court Filings; Order Thereon 1342597v1 36363/0015 Case No. 2:09-cv-03308-LKK-JFM

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

DATED: July 16, 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: July 16, 2010. MILLER STARR REGALIA By: /s/ Arthur F. Coon ARTHUR F. COON

Attorneys for Respondent California Department of Corrections and Rehabilitation DATED: July 16, 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: July 16, 2010. OFFICE OF THE SAN JOAQUIN COUNTY COUNSEL By: /s/ J. Mark Myles J. MARK MYLES

Attorneys for Petitioner County of San Joaquin

3
Request for Further Extension to Execute & Implement Settlement with Court Filings; Order Thereon 1342597v1 36363/0015 Case No. 2:09-cv-03308-LKK-JFM

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

DATED: July 16, 2010. OFFICE OF THE STOCKTON CITY ATTORNEY By: /s/ John Luebberke JOHN LUEBBERKE

Attorneys for Petitioner City of Stockton IT IS SO ORDERED.

DATED: July 20, 2010.

4
Request for Further Extension to Execute & Implement Settlement with Court Filings; Order Thereon 1342597v1 36363/0015 Case No. 2:09-cv-03308-LKK-JFM