Redd, et al v. Daley, et al
Filing
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STIPULATION AND ORDER re 221 STIPULATION WITH PROPOSED ORDER re 218 Clerks Notice, Joint Stipulation And [Proposed] Order To Continue Case Management Conference filed by Paul A. Redd, Jr. Case Management Statement due by 8/28/2014. Initial Case Management Conference set for 9/4/2014 09:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 4/29/14. (bpf, COURT STAFF) (Filed on 4/29/2014)
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RISHI N. SHARMA (Cal. State Bar No. 239034)
PETER A. COOPER (Cal. State Bar No. 275300)
PAUL HASTINGS LLP
55 Second Street, 24th Floor
San Francisco, California 94105
Telephone: (415) 856-7000
Facsimile: (415) 856-7100
rishisharma@paulhastings.com
petercooper@paulhastings.com
Attorneys for Plaintiff
Paul A. Redd, Jr.
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TRACE O. MAIORINO (Cal. State Bar No. 179749)
SHARON A. GARSKE (Cal. State Bar No. 215167)
Office of the Attorney General of the State of California
455 Golden Gate Avenue, Suite 11000
San Francisco, California 94102
Telephone: (415) 703-5975
Facsimile: (415) 703-5843
trace.maiorino@doj.ca.gov
sharon.garske@doj.ca.gov
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Attorneys for Defendant
Michael D. Daley
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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PAUL A. REDD, JR.,
No. C 98-20429 EMC
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Plaintiff,
JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE
vs.
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MICHAEL D. DALEY,
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Defendant.
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LEGAL_US_W # 78508207.3
JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. C 98-20429 EMC
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JOINT STIPULATION
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Pursuant to Local Rule 6-2, Plaintiff Paul A. Redd, Jr. and Defendant Michael D. Daley, by and
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through their respective counsel of record, hereby jointly stipulate and respectfully request the Court
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enter an order as follows:
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1.
On April 7, 2014, the Court granted the motion of Frank Michael Washko to withdraw as
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attorney of record for Plaintiff (ECF 216), and appointed Rishi N. Sharma and Peter A. Cooper of Paul
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Hastings LLP as pro bono counsel for purposes of settlement, pre-trial filings, and trial (ECF 217). On
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April 9, 2014, the Court set a case management conference for May 13, 2014. (ECF 218.)
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2.
The Parties respectfully request that the Court continue the case management conference
from May 13, 2014, to September 4, 2014, for the following reasons:
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a.
First, since the Court set the case management conference in this action, counsel
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have learned that Plaintiff will be transferred from Pelican Bay State Prison in Crescent City, California,
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to a state prison facility in Corcoran, California; however, for security reasons, the date of Plaintiff’s
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transfer has not been released. Because of the uncertainty surrounding the date of his transfer, as well as
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the extensive case file in this action, counsel have been unable to complete their review of the case file
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and communicate directly with Plaintiff regarding this action. Counsel for Plaintiff anticipate that they
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will be able to complete their review of the case file and communicate directly with Plaintiff shortly
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after the date of his transfer.
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b.
Second, Mr. Maiorino, counsel for Defendant, is on vacation until May 9, 2014.
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Similarly, Mr. Sharma, counsel for Plaintiff, is scheduled to be on vacation from May 21, 2014, to
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June 8, 2014.
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c.
Third, pursuant to Plaintiff’s request in his March 17, 2014, motion for
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appointment of pro bono counsel (ECF 215), counsel for the Parties anticipate seeking a further
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settlement conference before Magistrate Judge Vadas. As the settlement conference must be set in
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accordance with Magistrate Judge Vadas’s schedule, the availability of prison facilities, and the
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completion of Plaintiff’s transfer to the state prison facility in Corcoran, California, counsel for the
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Parties anticipate that it will take at least three months to seek and complete the further settlement
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conference. Accordingly, the Parties request a continuance of the case management conference to
LEGAL_US_W # 78508207.3
JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. C 98-20429 EMC
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permit a further settlement conference.
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Based on these reasons, the Parties’ respectfully request that the Court continue the
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May 13, 2014, case management conference to September 4, 2014, to allow Plaintiff’s transfer to be
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effected, to avoid counsel’s vacation schedules, and to permit the parties to seek and complete a further
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settlement conference before Magistrate Judge Vadas.
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Dated: April 29, 2014
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RISHI N. SHARMA
PETER A. COOPER
PAUL HASTINGS LLP
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By: /s/
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Peter A. Cooper
Peter A. Cooper
Attorneys for Plaintiff Paul A. Redd, Jr.
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Dated: April 29, 2014
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TRACE O. MAIORINO
SHARON A. GARSKE
OFFICE OF THE ATTORNEY GENERAL OF THE
STATE OF CALIFORNIA
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By: /s/
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Sharon A. Garske
Sharon A. Garske
Attorneys for Defendant Michael D. Daley
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LEGAL_US_W # 78508207.3
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JOINT STIPULATION & ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. C 98-20429 EMC
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ORDER
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On the stipulation of the Parties, and good cause appearing therefor,
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IT IS ORDERED that the May 13, 2014, case management conference in this action is continued
Dated: May __, 2014 4/29/14
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Edward M. Chen
United States District Judge
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. Chen
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to September 4, 2014, at 9:30 a.m. The case management statement is to be filed by August 28, 2014.
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LEGAL_US_W # 78508207.3
ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE
U.S.D.C., N.D. Cal., No. C 98-20429 EMC
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