Travis Unified School District v. Bell et al

Filing 37

STIPULATION and ORDER 36 signed by Senior Judge William B. Shubb on 11/7/2017 continuing deadline to serve Administrative Record by 12/15/2017.(Kirksey Smith, K)

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DANNIS WOLIVER KELLEY
275 BATTERY STREET, SUITE 1150
SAN FRANCISCO, CA 94111

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MATTHEW J. TAMEL, State Bar No. 229378
[e-mail]
KASMIRA M. BROUGH, State Bar No. 308791
[e-mail]
Dannis Woliver Kelley
275 Battery Street, Suite 1150
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415.543.4384
Attorneys for Plaintiff and Counter-Defendant
TRAVIS UNIFIED SCHOOL DISTRICT
F. RICHARD RUDERMAN, SB No. 142226
[e-mail]
COLLEEN A. SNYDER, SB No. 274064
[e-mail]
Ruderman & Knox, LLP
1300 National Drive, Suite 200
Sacramento, CA 95834
Telephone: [phone]
Facsimile: 916-563-0114
Attorneys for Defendants and Counter-Claimants
C.B., DEBRA BELL, AND DONALD BELL

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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TRAVIS UNIFIED SCHOOL
DISTRICT,
v.

Case No.

Plaintiff,

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Defendants.

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JOINT STIPULATION AND REQUEST TO
CONTINUE DEADLINE TO SERVE
ADMINISTRATIVE RECORD;
[PROPOSED] ORDER

DEBRA BELL and DONALD BELL,
individually and as parents on
behalf of C.B., a minor,

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2:17-CV-00808-WBS-AC

DEBRA BELL and DONALD BELL,
individually and as parents on
behalf of C.B., a minor,
T
Counter-Claimants,
v.

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Complaint Filed: April 18, 2017

TRAVIS UNIFIED SCHOOL
DISTRICT,
Counter-Defendant.
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DWK DMS
3183136v1

JOINT STIPULATION AND REQUEST TO CONTINUE DEADLINE TO SERVE ADMINISTRATIVE
RECORD; [PROPOSED] ORDER

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I.

STIPULATION
Travis Unified School District (“District”), Plaintiff and

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Counter-Defendant, and Debra and Donald Bell, individually and as

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parents on behalf of C.B., a minor, Defendants and Counter-

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Claimants, by and through their respective counsel, stipulate as

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follows:
1.

According to the Court’s Status (Pretrial Scheduling)
Order, Plaintiff shall provide Defendants a certified
copy of the administrative record no later than
November 15, 2017.

2.

On October 30, 2017, the Parties attended courtsponsored mediation which resulted in a tentative
settlement.

3.

On November 2, 2017, the Parties signed a settlement
agreement, which is subject to the approval of the
District’s Board of Education (“Board”). The Parties
anticipate that the settlement agreement will be
reviewed and approved by the Board at the next
regularly scheduled Board meeting on November 14, 2017.

4.

In the event that the Board approves the settlement,
the Parties have agreed to dismiss all claims filed in
this case.

5.

In anticipation of settling this case, and in the
interest of avoiding the unnecessary expenditure of
additional time and resources, the Parties have agreed
to extend the deadline to serve the administrative
record.

6.

The Parties therefore request that the Court continue
the deadline to serve the administrative record for
thirty days, to December 15, 2017, to allow the Parties
time to resolve this matter.

7.

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The Parties agree that all other deadlines should be
maintained for now, but reserve the right to seek
further continuances according to the Court’s rules.

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DANNIS WOLIVER KELLEY
275 BATTERY STREET, SUITE 1150
SAN FRANCISCO, CA 94111

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DWK DMS
3183136v1

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JOINT STIPULATION AND REQUEST TO CONTINUE DEADLINE TO SERVE ADMINISTRATIVE
RECORD; [PROPOSED] ORDER

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Respectfully submitted:
DATED: November 2, 2017

DANNIS WOLIVER KELLEY

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By: /s/ Matthew J. Tamel
MATTHEW J. TAMEL
KASMIRA M. BROUGH
Attorneys for Plaintiff /
Counter-Defendant
TRAVIS UNIFIED SCHOOL DISTRICT

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RUDERMAN & KNOX

DATED: November 6, 2017

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By: /s/ Colleen A. Snyder
F. RICHARD RUDERMAN
COLLEEN A. SNYDER
Attorneys for Defendants and
Counter-Claimants C.B., DEBRA
BELL, AND DONALD BELL

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DANNIS WOLIVER KELLEY
275 BATTERY STREET, SUITE 1150
SAN FRANCISCO, CA 94111

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IT IS SO ORDERED.

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Dated:

November 7, 2017

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DWK DMS
3183136v1

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JOINT STIPULATION AND REQUEST TO CONTINUE DEADLINE TO SERVE ADMINISTRATIVE
RECORD; [PROPOSED] ORDER