T., et al v. Sacramento City School District

Filing 15

STIPULATION AND ORDER signed by District Judge Morrison C. England, Jr. on 05/17/16 ORDERING that plaintiffs' opening memorandum in support of an award of attorneys' fees is due by 07/22/16; District's opposition due by 08/19/16; plaintiffs' reply due no later than 14 days after the District's opposition is filed; and a hearing is set for 09/22/16 at 2:00 p.m. before District Judge Morrison C. England, Jr. (Benson, A)

1 Sloan R. Simmons, SBN 233752
[e-mail]
2 Sarah L. Garcia, State Bar No. 233814
[e-mail]
3 Carey H. Ash, State Bar No. 303872
[e-mail]
4 LOZANO SMITH
One Capitol Mall, Suite 640
5 Sacramento, CA 95814
Telephone:
[phone]
6 Facsimile:
[phone]
7 Attorneys for Defendant
SACRAMENTO CITY UNIFIED
8 SCHOOL DISTRICT
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LOZANO SMITH
One Capitol Mall, Suite 640 Sacramento, CA 95814
Tel [phone] Fax [phone]

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

12 JAY T. and ANNE M.-T., individually, and as
guardian ad litem for M.M.-T.,
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Plaintiffs,
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vs.
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SACRAMENTO CITY UNIFIED SCHOOL
16 DISTRICT,
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Case No. 2:16-cv-00136-MCE-AC
JOINT STIPULATION RE: BRIEFING
AND HEARING SCHEDULE; ORDER
THEREON

Defendant.

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____________________________________________________________________________________________________
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JOINT STIP. RE: BRIEFING & HEARING SCHEDULE;
Jay T., et al. v. SCUSD
[PROPOSED] ORDER
Case No.2:16-cv-00136-MCE-AC

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TO THE HONORABLE COURT:

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IT IS HEREBY STIPULATED by and between PLAINTIFFS Jay T. and Anne M.-T.,

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individually, and as guardian ad litem for M.M.-T. (“Plaintiffs”), through their counsel of record, and

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DEFENDANT Sacramento City Unified School District (“District” and referred to with Plaintiffs as,

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“Parties”), through its counsel of record, as follows:

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1.

The Parties agree that discovery is unnecessary and inappropriate in this action;

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2.

The Parties agree that in terms of both causes of action in Plaintiffs’ Complaint, the only

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issue before the Court is Plaintiffs’ claim(s) for attorneys’ fees;
3.

The Parties agree that said cause of actions and claim(s) for attorneys’ fees in Plaintiffs’

LOZANO SMITH
One Capitol Mall, Suite 640 Sacramento, CA 95814
Tel [phone] Fax [phone]

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Complaint should be appropriately resolved via the normal process of claiming and adjudication of

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claims for attorneys’ fees, i.e., through a motion and briefing schedule and hearing;

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4.

The Parties therefore agree to the following briefing and hearing schedule for resolution

of the merits of the causes of action and claim(s) for attorneys’ fees in Plaintiffs’ Complaint:
a.

Plaintiffs’ opening memorandum in support of an award of attorneys’ fees

(limited to 25 pages) and supporting papers, shall be filed on or before July 22, 2016;
b.

District’s opposition memorandum (limited to 25 pages) and supporting papers

shall be filed on or before August 19, 2016;
c.

Plaintiffs’ reply memorandum (limited to 15 pages) and supporting papers shall

be filed by no later than 14 days after the District’s opposition memorandum is filed; and
d.

That a hearing be set for September 22, 2016 on the merits of the above motion

papers/briefing, should the Court deem such a hearing necessary.

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Dated: May ___, 2016

Respectfully submitted,
RUDERMAN & KNOX, LLP
/s/ Colleen A. Snyder
RICHARD RUDERMAN
COLLEEN A. SNYDER
Attorney for Plaintiffs Jay T. and Anne M.-T., individually
and as guardians ad litem for M.M.-T.

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JOINT STIP. RE: BRIEFING & HEARING SCHEDULE;
ORDER THEREON

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Jay T., et al. v. SCUSD
Case No. 2:16-cv-00136-MCE-AC

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Dated: May ___, 2016

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Respectfully submitted,
LOZANO SMITH

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/s/ Sloan R. Simmons
SLOAN R. SIMMONS
SARAH L. GARCIA
CAREY H. ASH
Attorneys for Defendant
SACRAMENTO CITY UNIFIED SCHOOLDISTRICT

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LOZANO SMITH
One Capitol Mall, Suite 640 Sacramento, CA 95814
Tel [phone] Fax [phone]

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ORDER
Based upon the foregoing Stipulation between PLAINTIFFS Jay T. and Anne M.-T.,
individually, and as guardian ad litem for M.M.-T. (“Plaintiffs”) and DEFENDANT Sacramento City
Unified School District (“District”), and GOOD CAUSE APPEARING THEREFORE:
The Court hereby orders the following briefing and hearing schedule in this action:
1.

Plaintiffs’ opening memorandum in support of an award of attorneys’ fees (limited to 25

pages) and supporting papers, shall be filed on or before July 22, 2016;
2.

District’s opposition memorandum (limited to 25 pages) and supporting papers shall be

filed on or before August 19, 2016;
3.

Plaintiffs’ reply memorandum (limited to 15 pages) and supporting papers shall be filed

by no later than 14 days after the District’s opposition memorandum is filed; and
4.

A hearing is set for September 22, 2016 at 2:00 p.m. on the merits of the motion.

IT IS SO ORDERED.
Dated: May 17, 2016

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JOINT STIP. RE: BRIEFING & HEARING SCHEDULE;
ORDER THEREON

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Jay T., et al. v. SCUSD
Case No. 2:16-cv-00136-MCE-AC