T., et al v. Sacramento City School District

Filing 25

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 9/29/16 ORDERING the briefing schedule in this action to be extended, as follows: District's Opposition Memorandum (limited to 25 pages) and supporting papers shall be filed on or before October 14, 2016; and plaintiffs' Reply Memorandum (limited to 15 pages) and supporting papers shall be filed by no later than November 4, 2016; The hearing on the merits in this matter set for November 17, 2016, at 2:00 p.m., shall remain on calendar as scheduled.(Becknal, R)

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

11 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
15 DISTRICT,
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Case No. 2:16-cv-00136-MCE-DB
JOINT STIPULATION RE: EXTENSION
OF BRIEFING SCHEDULE; ORDER
THEREON

Defendant.

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JOINT STIP. RE: EXTENSION OF BRIEFING
Jay T., et al. v. SCUSD
Case No.2:16-cv-00136-MCE-DB
SCHEDULE; ORDER THEREON

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TO THE HONORABLE COURT:

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IT IS HEREBY STIPULATED, pursuant to Local Rules 143 and 144, by and between

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PLAINTIFFS Jay T. and Anne M.-T., individually, and as guardian ad litem for M.M.-T. (“Plaintiffs”),

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through their counsel of record, and DEFENDANT Sacramento City Unified School District (“District”

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and referred to with Plaintiffs as, “Parties”), through its counsel of record, as follows:

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1.

On May 16, 2016, the parties agreed, via stipulation, to the following briefing and

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hearing schedule: (a) Plaintiffs’ Opening Memorandum to be filed on or before July 22, 2016;

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(b) District’s Opposition Memorandum to be filed on or before August 19, 2016; (c) Plaintiff’s Reply

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Brief to be filed within fourteen days of filing of Opposition Brief; and (d) Hearing on September 22,

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

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2016.

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2.

On May 17, 2016, the Court ordered the briefing and hearing schedule as proposed by the

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On July 11, 2016, based upon stated reasons, the parties stipulated to the extension of the

parties.

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ordered briefing and hearing schedule, which the Court so ordered on July 12, 2016. Based upon the

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Court’s order: (a) Plaintiffs' Opening Memorandum in Support of an Award of Attorneys’ Fees was to

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be filed on or before August 31, 2016; (b) the District’s Opposition Memorandum was to be filed on or

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before September 30, 2016; (c) Plaintiffs’ Reply Memorandum was to be filed by no later than 14 days

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after the District's Opposition Memorandum is filed; and (d) a hearing on the merits was scheduled for

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November 17, 2016 at 2:00 p.m. in Courtroom 7 before District Judge Morrison C. England Jr.

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4.

On August 31, 2016, Plaintiffs filed their opening memorandum and supporting papers.

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5.

Due to the unforeseen leave of absence of one of the District’s attorneys primarily

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responsible for this matter, including the preparation of the District’s opposition memorandum and

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supporting papers, and impacts on this case and other pending matters as a result of same, counsel for

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the District requested, and counsel for Plaintiffs agreed, to extend the remaining briefing schedule in this

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case, as follows: (a) District’s Opposition Memorandum (limited to 25 pages) and supporting papers

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shall be filed on or before October 14, 2016; and (b) Plaintiffs’ Reply Memorandum (limited to 15

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pages) and supporting papers shall be filed by no later than November 4, 2016. The parties also agreed

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JOINT STIP. RE: EXTENSION OF BRIEFING
SCHEDULE; ORDER THEREON

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

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that the ordered hearing on the merits in this matter may remain on calendar for November 17, 2016 as

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scheduled.

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There has been only one previous modification to the proposed briefing and hearing

schedule in this matter.

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Accordingly, the parties request approval for this agreed-upon modification to the

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briefing schedule.

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Dated: September 26, 2016

RUDERMAN & KNOX, LLP

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/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.

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

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Respectfully submitted,

Dated: September 26, 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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JOINT STIP. RE: EXTENSION OF BRIEFING
SCHEDULE; ORDER THEREON

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

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ORDER
Based upon the foregoing Stipulation between PLAINTIFFS Jay T. and Anne M.-T.,

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individually, and as guardian ad litem for M.M.-T. (“Plaintiffs”) and DEFENDANT Sacramento City

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Unified School District (“District”), and good cause appearing,

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The Court hereby orders the briefing schedule in this action to be extended, as follows:

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1.

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

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District’s Opposition Memorandum (limited to 25 pages) and supporting papers shall be

filed on or before October 14, 2016; and
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Plaintiffs’ Reply Memorandum (limited to 15 pages) and supporting papers shall be filed

by no later than November 4, 2016.
The hearing on the merits in this matter set for November 17, 2016, at 2:00 p.m., shall remain on
calendar as scheduled.
IT IS SO ORDERED.
Dated: September 29, 2016

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JOINT STIP. RE: EXTENSION OF BRIEFING
SCHEDULE; ORDER THEREON

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