Ambat et al v. City & County of San Francisco et al

Filing 402

ORDER, Motions terminated: 401 STIPULATION WITH PROPOSED ORDER Re Removal of Case from Trial Calendar filed by City and County of San Francisco. Further Case Management Conference set for 8/7/2015 03:00 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 4/3/15. (tfS, COURT STAFF) (Filed on 4/6/2015)

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DENNIS J. HERRERA (SBN 139669)
City Attorney
ELIZABETH S. SALVERSON (SBN 83788)
Chief Labor Attorney
JONATHAN ROLNICK (SBN 151814)
Deputy City Attorneys
Fax Plaza
1390 Market Street, Fifth Floor
San Francisco, CA 94102
Tel: [phone] Fax: [phone]
Attorneys For Defendants CITY AND COUNTY OF SAN FRANCISCO, et al
DANIEL H. BROMBERG (SBN 242659)
JORDAN JAFFE (SBN 254886)
Quinn Emanuel Urquhart & Sullivan, LLP
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, CA 94065
Tel: [phone] Fax: [phone]
Attorneys for Plaintiff Jon Gray

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LAWRENCE D. MURRAY (SBN 77536)
ROBERT C. STRICKLAND (SBN 243757)
Murray & Associates
1781 Union Street
San Francisco, CA 94123
Tel: [phone] Fax: [phone]
Attorneys for Plaintiffs except Jon Gray

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MERCY AMBAT, et al,

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Plaintiffs,
vs.

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No. CV 07-03622 SI
(including No: C-08-2406 SI & C-09-2652 SI)

CITY AND COUNTY OF SAN FRANCISCO,

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Defendants.

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STIPULATION FOR ORDER AND ORDER
REMOVING MATTER FROM TRIAL AND
FINAL PRETRIAL CONFERENCE CALENDAR
AND SETTING THE MATTER FOR CASE
MANAGEMENT CONFERENCE

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IT IS HEREBY STIPULATED by and between the parties, through their respective counsel,

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that:
Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI

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Stipulation For Order Removing Matter From Trial And Final Pretrial Calendar And Setting The A CMC

(a)

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Plaintiffs and Defendant are currently set for Final Pretrial Conference in this court

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on April 21, 2015, and for Jury Trial on April 27, 2015, on all of the claims

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remaining in the Third Amended Complaint.
(b)

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The parties have prepared to go forward with trial. In addition, the parties spent April
2, 2015, in mediation with the Honorable James McBride (retired Judge of the

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Superior Court).
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(c)
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As a result of the mediation with Judge McBride, the parties have and do agree in
principle to settle and resolve all of their disputes.

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(d)

They are currently in the process of preparing the necessary documents to effectuate a
settlement including:

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(1) submission of the Settlement Agreement and Release to the San Francisco

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Board of Supervisors for approval, which may take up to 90 days;

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(2) preparation of a Settlement Agreement and Release to be signed by all
plaintiffs, save and except possibly Plaintiff Anderson;

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(3) in the event Plaintiff Anderson cannot be located, that her settlement be
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confirmed as full, fair and appropriate compensation with authority from the
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Court for her attorneys to dismiss her claim on funding;

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(4) for the appointment of a Referee, the Honorable James McBride, to

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recommend distribution of the settlement proceeds amongst the Plaintiffs,

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with final distribution to be authorized by a hearing before this Court to take

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objections to such distribution and issue the final order for distribution; and

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(5) schedule the CMC with sufficient time for progress on funding, distribution
and settlement documents.

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(e)

The parties therefore respectfully request that the matter be removed from the Final

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Pretrial Conference Calendar and the Jury Trial Calendar, and be placed on the Case
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Management calendar 60 days from this date to review progress of the settlement.
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Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI

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Stipulation For Order Removing Matter From Trial And Final Pretrial Calendar And Setting The A CMC

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SO STIPULATED:

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Date: April 3, 2015

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MURRAY & ASSOCIATES

SAN FRANCISCO CITY ATTORNEY OFFICE

_/s/ Lawrence D. Murray _____
Lawrence D. Murray
Attorney for Plaintiffs except Jon Gray

/s/ Jonathan Rolnick___
Jonathan Rolnick
Attorney for Defendants City and County of San
Francisco, et al.

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QUINN EMANUEL URQUHART & SULLIVAN, LLP

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/S/ Daniel H. Bromberg
Daniel H. Bromberg
Quinn Emanuel Urquhart & Sullivan, LLP
Attorneys for Plaintiff Jon Gray

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ORDER ON STIPULATION FOR ORDER

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HAVING READ AND CONSIDERED THE FOREGOING, and good cause appearing:

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The foregoing is the order of the court. The new Case Management Conference Date is

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August 7, 2015
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3:00 p.m.
_______________________ at the hour of _____________ in Courtroom _____________.

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Date: 4/3/15

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________________________________________
SUSAN ILLSTON
UNITED STATES DISTRICT COURT JUDGE

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Ambat et al. v. CCSF et al.; United States District Court, Northern District of Calif. Case No. C 07-3622 SI

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Stipulation For Order Removing Matter From Trial And Final Pretrial Calendar And Setting The A CMC