Porter et al v. Solano County Sheriff's Office et al

Filing 130

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 7/3/2024 MODIFYING the page limits on pleadings related to Motions for Summary Judgment. (Woodson, A)

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1 2 3 4 5 6 7 8 Danielle K. Lewis (SBN 218274) dlewis@hpylaw.com Miles F. Maurino. (SBN 319377) mmaurino@hpylaw.com HAWKINS PARNELL & YOUNG, LLP 33 New Montgomery, Suite 800 San Francisco, CA 94105 Telephone: (415) 766-3200 Facsimile: (415) 766-3250 Yasin M. Almadani (Cal. Bar No. 242798) ALMADANI LAW 4695 MacArthur Ct., Suite 1100 Newport Beach, CA 92660 Tel: (949) 877-7177 Fax: (949) 877-8757 YMA@LawAlm.com Attorneys for Defendants County of Solano, Solano County Sheriff’s Office, Sheriff Thomas A. Ferrara, Dalton McCampbell, Lisa McDowell, Connor Hamilton, and Chris Carter 11 Gregory M. Fox (SBN 70876) BERTRAND, FOX, ELLIOT, OSMAN & WENZEL 2749 Hyde Street San Francisco, CA 94109 Telephone: (415) 353-0999 Email: gfox@bfesf.com 12 Attorneys for Defendant Roy Stockton 9 10 13 EASTERN DISTRICT OF CALIFORNIA 15 17 18 19 20 21 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT 14 16 Ahmed Ibrahim (Cal. Bar No. 238739) AI LAW, PLC 4695 MacArthur Ct., Suite 1100 Newport Beach, CA 92660 Tel: (949) 266-1240 Fax: (949) 266-1280 aibrahim@ailawfirm.com SACRAMENTO DIVISION NAKIA V. PORTER, et al., Case No. 2:21-CV-01473-KJM-JDP STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT Plaintiffs, v. COUNTY OF SOLANO, et al., Defendants. Hon. Kimberly J. Mueller Chief United States District Judge 22 23 Plaintiffs Nakia Porter, on behalf of herself and her minor children, L.P. and A.P., Joe Berry 24 Powell, Jr., and Clifton Powell, on behalf of his minor child O.P., (collectively “Plaintiffs”) by and 25 through their counsel of record, Yasin M. Almadani and Ahmed Ibrahim, Defendants County of Solano, 26 Solano County Sheriff’s Office, Sheriff Thomas A. Ferrara, Dalton McCampbell, Lisa McDowell, 27 Connor Hamilton, and Chris Carter (collectively “County Defendants”), by and through their counsel of 28 1 STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT 2:21-CV-01473-KJM-JDP 1 record, Danielle K. Lewis, and Defendant Roy Stockton, by and through his counsel of record, Gregory 2 M. Fox, (collectively together “Defendants”) hereby stipulate to modify the page limits for all parties’ 3 motion for summary judgment. 4 The parties hereby stipulate that: 5 1. The operative Complaint is Plaintiff’s Second Amended Complaint. (ECF No. 15) 6 2. The Second Amended Complaint consists of thirteen causes of action, 195 paragraphs, 7 spans 49 pages in length, and alleges causes of action against seven separate defendants. In addition, 8 there are five total Plaintiffs, which consist of two adults and three minors. 9 3. Plaintiffs intend to file a motion for summary judgment/adjudication. Both County 10 Defendants, as well as Defendant Roy Stockton, also intend to file separate motions for summary 11 judgment/adjudication. The parties have begun to meet and confer regarding the issues to be addressed 12 in the parties’ respective motions for summary judgment/adjudication. 13 4. County Defendants are represented by Danielle K. Lewis and Miles Maurino of Hawkins 14 Parnell & Young, LLP. Separately, Defendant Roy Stockton is represented by Greg Fox of Bertrand, 15 Fox, Elliot, Osman & Wenzel. 16 5. County Defendants and Defendant Roy Stockton intend to file separate motions for 17 summary judgment, based on the disparate allegations made against the County Defendants, and 18 Defendant Roy Stockton. 19 6. On February 22, 2024, the Court issued an Order modifying case deadlines, which dictated 20 that “All dispositive motions, except for motions for continuances, temporary restraining orders or other 21 emergency applications, shall be filed by July 15, 2024. Oppositions shall be filed by August 12, 2024, 22 and replies shall be filed by August 26, 2024.” (ECF No. 107) 23 7. The case is assigned to the Honorable Chief District Judge Kimberly Mueller, whose 24 standing order which states that the “Memorandum of Points and Authorities in support of or in 25 opposition to motions shall not exceed twenty pages. Replies shall not exceed ten (10) pages. Only in 26 rare instances and for good cause shown will the court grant an application to extend these page 27 limitations. All requests for page limit increases must be made in writing at least fourteen (14) days prior 28 2 STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT 2:21-CV-01473-KJM-JDP 1 to the filing of the motion.” (Hon. Judge Kimberly J. Mueller Civil Standing Order, Section 4(B)) 2 8. Counsel for Plaintiffs and Defendants have met and conferred regarding a stipulation to 3 increase the page limits. Both parties agree that an increase to page limits of all memorandum of points 4 of authorities in support of a motion for summary judgment/adjudication, all oppositions, and all replies 5 warrant a modest increase to reflect the volume of allegations, causes of action, and parties. 6 9. Specifically, the parties hereby stipulate to increase the page limit to any memorandum of 7 points and authorities in support of a motion for summary judgment/adjudication from 20 pages to 30 8 pages. 9 10 11 12 10. The parties hereby stipulate to increase the page limit to any opposition to a motion for summary judgment/adjudication from 20 pages to 30 pages. 11. The parties hereby stipulate to increase the page limits to any reply to an opposition to a motion for summary judgment/adjudication from 10 pages to 15 pages. 13 12. This stipulation does not seek to modify any other case deadlines. 14 13. No trial date has been set. 15 14. This stipulation is being filed in good faith and not for purposes of delay. 16 15. The parties submit that the foregoing demonstrates good cause to grant the request in this 17 18 Stipulation. IT IS SO STIPULATED 19 20 Dated: June 27, 2024 /s/ Yasin M. Almadani Yasin M. Almadani, Esq. 21 22 23 Dated: June 27, 2024 24 Attorneys for Plaintiffs 26 28 AI LAW, PLC /s/ Ahmed Ibrahim Ahmed Ibrahim, Esq. 25 27 ALMADANI LAW Dated: June 27, 2024 HAWKINS PARNELL & YOUNG 3 STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT 2:21-CV-01473-KJM-JDP 1 /s/ Danielle K. Lewis Danielle K. Lewis, Esq. Miles F. Maurino, Esq. 2 3 Attorneys for Defendants County of Solano, Solano County Sheriff’s Office, Sheriff Thomas A. Ferrara, Dalton McCampbell, Lisa McDowell, Connor Hamilton, and Chris Carter 4 5 6 7 Dated: June 27, 2024 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL 8 /s/ Gregory M. Fox Gregory M. Fox, Esq. 9 Attorneys for Defendant Roy Stockton 10 11 12 13 14 FILER'S ATTESTATION 15 16 17 18 I hereby attest that I have been authorized by counsel to show their signature on this document as /s/. DATED: June 27, 2024 /s/ Danielle K. Lewis DANIELLE K. LEWIS 19 20 21 22 23 24 25 26 27 28 4 STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT 2:21-CV-01473-KJM-JDP ORDER 1 2 The foregoing stipulation of the parties is approved, and IT IS SO ORDERED. 3 A memorandum of points and authorities in support of a motion for summary 4 judgment/adjudication shall be 30 pages. 5 An opposition to a motion for summary judgment/adjudication shall be 30 pages. 6 A reply to an opposition to a motion for summary judgment/adjudication shall be 15 pages. 7 DATED: July 3, 2024. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 STIPULATION AND ORDER TO MODIFY THE PAGE LIMITS IMPOSED ON ALL PARTIES’ PLEADINGS RELATED TO MOTIONS FOR SUMMARY JUDGMENT, AND CROSS-MOTIONS FOR SUMMARY JUDGMENT 2:21-CV-01473-KJM-JDP

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