S. et al v. Fremont Unified School District

Filing 205

Order to Replace Exhibits A and B to the District's Requst for Judicial Notice in Opposition to Plaintiff's Daubert Motion with Redacted Versions by Fremont Unified School District re 203 . (tf, COURT STAFF) (Filed on 11/24/2009)

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Case3:06-cv-07218-SI Document203 Filed11/19/09 Page1 of 2 1 2 3 4 5 6 7 8 MILLER BROWN & DANNIS 71 STEVENSON STREET, 19TH FLOOR SAN FRANCISCO, CA 94105 AMY R. LEVINE, State Bar No. 160743 alevine@mbdlaw.com DAMARA MOORE, State Bar No. 215678 dmoore@mbdlaw.com SARAH L. W. SUTHERLAND, State Bar No. 239889 ssutherland@mbdlaw.com MILLER BROWN & DANNIS 71 Stevenson Street, 19th Floor San Francisco, CA 94105 Telephone: (415) 543-4111 Attorneys for Defendant FREMONT UNIFIED SCHOOL DISTRICT UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 v. K.S., a minor, by and through her parents, P.S. and M.S., Plaintiff, Case No. C06 7218 SI STIPULATION AND [PROPOSED] ORDER TO REPLACE EXHIBITS A AND B TO THE DISTRICT'S REQUEST FOR JUDICIAL NOTICE IN OPPOSITION TO PLAINTIFF'S DAUBERT MOTION WITH REDACTED VERSIONS Judge: Hon. Susan Illston FREMONT UNIFIED SCHOOL DISTRICT, Defendant. Third Amended Complaint Filed: September 11, 2009 The parties hereto by and through their counsel of record hereby stipulate and agree to substitute documents filed by defendant FREMONT UNIFIED SCHOOL DISTRICT ("District") on November 11, 2009, with redacted versions of those documents. The documents to be removed are the two exhibits attached to the District's Request for Judicial Notice in Opposition to Plaintiff's Daubert Motion to Exclude Certain Expert Opinion Testimony and Report of Dr. Bryna Siegel, identified as Exhibit A, a twelve page document dated March 23, 2009 (Document 201-19) and Exhibit B, a nine page document dated May 12, 2009 (Document 201-20). The documents to 1 STIPULATION AND [PROPOSED] ORDER TO REPLACE EXHIBITS A AND B TO THE DISTRICT'S REQUEST FOR JUDICIAL NOTICE IN OPPOSITION TO PLAINTIFF'S DAUBERT MOTION WITH REDACTED VERSIONS; CASE NO. C06-7218 SI SF 403672v1 Case3:06-cv-07218-SI Document203 Filed11/19/09 Page2 of 2 1 2 3 4 5 6 7 8 MILLER BROWN & DANNIS 71 STEVENSON STREET, 19TH FLOOR SAN FRANCISCO, CA 94105 be substituted are the attached documents Exhibit A and Exhibit B, which are identical to those originally filed but for redactions to prevent disclosure of confidential information. Good cause exists for the substitution of these documents for the original District documents filed as Document 201-19 and 201-20, because the originally filed Documents 201-19 and 201-20 included Plaintiff/student and her parents' names. Plaintiff filed this case under a pseudonym, and this information is confidential. DATED: November 19, 2009 MILLER BROWN & DANNIS 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION AND [PROPOSED] ORDER TO REPLACE EXHIBITS A AND B TO THE DISTRICT'S REQUEST FOR JUDICIAL NOTICE IN OPPOSITION TO PLAINTIFF'S DAUBERT MOTION WITH REDACTED VERSIONS; CASE NO. C06-7218 SI By: /s/ DAMARA MOORE AMY R. LEVINE DAMARA MOORE SARAH L. W. SUTHERLAND Attorneys for Defendant FREMONT UNIFIED SCHOOL DISTRICT DATED: November 19, 2009 LEIGH LAW GROUP DBA EDULEGAL By: /s/ MANDY G. LEIGH MANDY G. LEIGH Attorneys for Plaintiff K.S., a minor, by and through her parents, P.S. and M.S. IT IS SO ORDERED. DATED: Hon. Susan Illston United States District Court Judge SF 403672v1

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