Fairfield-Suisun Unified School District

Filing 9

STIPULATION AND ORDER signed by Judge John A. Mendez on 3/6/12 ORDERING that the parties have agreed to jointly submit an Amended Rule 26(f) Joint Status Report within thirty (30) days of the date of the Court's ruling on Defendant's Motion to Dismiss, if appropriate. (Becknal, R)

1 Roy A. Combs, SBN 123507
[e-mail]
2 Jan E. Tomsky, SBN 173131
[e-mail]
3 Emily E. Sugrue, SBN 243710
[e-mail]
4 FAGEN FRIEDMAN & FULFROST, LLP
70 Washington Street, Suite 205
5 Oakland, California 94607
Phone: [phone]
6 Fax: [phone]
7 Attorneys for Fairfield-Suisun Unified School
District
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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70 Washington Street, Suite 205
Oakland, California 94607
Main: 510-550-8200 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

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12 FAIRFIELD SUISUN UNIFIED SCHOOL
DISTRICT,
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Plaintiff,
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vs.
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STATE OF CALIFORNIA DEPARTMENT
16 OF EDUCATION, and DOES 1-25, inclusive,

CASE NO. 2:11-CV-02796-JAM-GGH
JOINT STIPULATION AND ORDER TO
SUBMIT AMENDED RULE 26(f) JOINT
STATUS REPORT

Defendant.

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SUBJECT TO THE APPROVAL OF THIS COURT, THE PARTIES HEREBY STIPULATE TO
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THE FOLLOWING:
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1.

On or about February 27, 2012, the parties, through their respective counsel of

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record, engaged in the Rule 26 conference telephonically to discuss those items required by Rule
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26(f) as well those matters specified in the court's Order Requiring Joint Status Report.
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2.

As part of the conference outcome, and subject to the Court's approval, the parties

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have agreed to jointly submit a Rule 26(f) Joint Status Report addressing those issues set forth in
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Paragraph 4 of the Order Requiring Joint Status Report excepting that a detailed discussion and
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agreement regarding the Rule 26(f) discovery plan, proposed date by which all non-discovery
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motions shall be filed, proposed dates for final pretrial conference and trial as well as a
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1
JOINT STIPULATION AND [PROPOSED] ORDER TO SUBMIT AMENDED RULE 26(f) JOINT STATUS
REPORT

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1 determination regarding the need to schedule a settlement conference for the above-referenced
2 matter would be deferred until after the Court's ruling on Defendant's Motion to Dismiss if
3 appropriate, and if appropriate shall be set forth in an Amended Rule 26(f) Joint Status Report.
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3.

Consistent with the foregoing and subject to the Court's approval, the parties have

5 agreed to jointly submit the Amended Rule 26(f) Joint Status Report within thirty (30) days of the
6 date of the Court's ruling on Defendant's Motion to Dismiss, if appropriate.
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SO STIPULATED.
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9 DATED: March 5, 2012

FAGEN FRIEDMAN & FULFROST, LLP

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70 Washington Street, Suite 205
Oakland, California 94607
Main: 510-550-8200 • Fax: [phone]

Fagen Friedman & Fulfrost, LLP

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By: /s/ Roy A. Combs
Roy A. Combs
Attorneys for Plaintiff

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15 DATED: March 5, 2012
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/s/ Len Garfinkel
Len Garfinkel
California Department of Education
Attorney for Defendant

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ORDER

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20 IT IS SO ORDERED.
DATED: 3/6/2012
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/s/ John A. Mendez_______________________
UNITED STATES DISTRICT COURT JUDGE

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JOINT STIPULATION AND [PROPOSED] ORDER TO SUBMIT AMENDED RULE 26(f) JOINT STATUS
REPORT

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