Clark, et al v. State of California, et al
Filing
514
ORDER regarding participation in defendants' strike teams re 513 Stipulation filed by State of California. Signed by Judge Charles R. Breyer on 7/22/2011. (beS, COURT STAFF) (Filed on 7/22/2011)
Case3:96-cv-01486-CRB Document513
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Filed07/19/11 Page1 of 3
KAMALA D. HARRIS
Attorney General of California
JONATHAN L. WOLFF
Senior Assistant Attorney General
DANIELLE F. O’BANNON
Deputy Attorney General
JOSE A. ZELIDON-ZEPEDA
Deputy Attorney General
State Bar No. 227108
455 Golden Gate Avenue, Suite 11000
San Francisco, CA 94102-7004
Telephone: (415) 703-5781
Fax: (415) 703-5843
E-mail: Jose.ZelidonZepeda@doj.ca.gov
Attorneys for Defendants State of California, et al.
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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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DERRICK CLARK, et al.,
C 96-1486 CRB
Plaintiffs, STIPULATION REGARDING
PLAINTIFFS’ COUNSEL’S
PARTICIPATION IN DEFENDANTS’
STRIKE TEAMS; [PROPOSED] ORDER
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v.
STATE OF CALIFORNIA, et al.,
Judge
The Honorable Charles R.
Breyer
Action Filed: April 22, 1996
Defendants.
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The parties stipulate that:
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1. On September 16, 2010, this Court issued its Findings of Facts and Conclusions of Law
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denying Defendants’ Motion to Terminate the Settlement Agreement. (Doc. 500.)
2. Since that date, the parties have conferred about steps to address the issues identified by
the Court in its Findings of Fact and Conclusions of Law.
3. Defendants have developed “strike teams” composed of CDCR staff and administrators
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to travel to the various institutions housing inmates in the Developmental Disability Program to
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improve compliance with the Clark Remedial Plan and this Court’s orders.
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Stip. Re: Strike Teams (C 96-1486 CRB)
Case3:96-cv-01486-CRB Document513
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Filed07/19/11 Page2 of 3
4. Plaintiffs’ counsel will be participating as part of the “strike team” concept at these
institutions.
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5. The parties agree that they will not use any information learned or evidence gathered
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during these “strike team” visits for any litigation purpose. The parties further agree that such
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information or evidence shall be deemed inadmissible under Federal Rule of Evidence 408.
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6. This stipulation does not bind Defendants to implement or maintain the “strike teams,”
or their current composition.
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Dated: 7/19/2011
/s/ Sara Norman
Sara Norman, Esq.
Prison Law Office
Counsel for Plaintiffs
Dated: 7/19/2011
/s/ Jose A. Zelidon-Zepeda
Jose A. Zelidon-Zepeda
California Attorney General’s Office
Counsel for Defendants
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July 22, 2011
Dated: __________
UNIT
ED
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NO
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O ORD
IT IS S
harle
Judge C
United States District Judge
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RT
U
O
S DISTRICT
TE
C
_____________________________
TA
Honorable Charles R. Breyer
CF1997CS0006
20446361.doc
RT
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ERED
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yer
s R. Bre
ER
H
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R NIA
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Per the parties’ stipulation, IT IS SO ORDERED.
FO
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LI
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A
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N
F
D IS T IC T O
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C
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Stip. Re: Strike Teams (C 96-1486 CRB)
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