Committee for Immigrant Rights of Sonoma County et al v. County of Sonoma et al

Filing 141

STIPULATION AND ORDER RE BRIEFING AND HEARING SCHEDULE ON MOTIONS TO DISMISS SECOND AMENDED COMPLAINT re 137 Stipulation filed by Bill Cogbill, Morris Eric Salkin, County of Sonoma. Signed by Judge Phyllis J. Hamilton on 10/15/09. (nah, COURT STAFF) (Filed on 10/15/2009)

1 THOMAS F. BERTRAND, State Bar No. 056560 RICHARD W. OSMAN, State Bar No. 167993 2 BERTRAND, FOX & ELLIOT The Waterfront Building 3 2749 Hyde Street San Francisco, CA 94109 4 Telephone: [phone] Facsimile: [phone] 5 E-mail: [e-mail] 6 STEVEN M. WOODSIDE State Bar No. 58684 7 ANNE L. KECK, State Bar No. 136315 8 County of Sonoma
Deputy County Counsel County Counsel

9 Santa Rosa, California 95403-2815 10 Facsimile: [phone] 11
Attorneys for Defendants Telephone: [phone]

575 Administration Drive, Room 105

E-mail: [e-mail]

12 County of Sonoma, Sheriff-Coroner William 13 14 15 16 17 COMMITTEE FOR IMMIGRANT RIGHTS 18 19 20 21 22 23
v. COUNTY OF SONOMA, et al., Defendants. / OF SONOMA COUNTY, et al., Plaintiffs, No. CV-08-4220-PJH JOINT STIPULATION RE BRIEFING AND HEARING SCHEDULE ON MOTIONS TO DISMISS SECOND AMENDED COMPLAINT; [PROPOSED] ORDER [NO HEARING SET] Cogbill, Deputy Sheriff Morris Eric Salkin

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

The parties herein, through their respective counsel of record, hereby agree and stipulate as

24 follows. 25
1. Pursuant to stipulation and order entered in this case on September 9, 2009, (Docket

26 No. 134), Plaintiffs filed their Second Amended Complaint on September 14, 2009 (the "complaint"). 27 The complaint consists of 74 pages and includes 22 causes of action (many of which contain several 28 sub-parts) seeking injunctive and declaratory relief as well as damages (compensatory and punitive).

Joint Stipulation re Briefing and Hearing Schedule on Motions To Dismiss Second Amended Complaint; [Proposed] Order

USDC Case No. CV-08-4220 PJH

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2.

All Defendants intend to file motions to dismiss the complaint on the stipulated due

2 date of October 29, 2009 (see Docket No. 134). 3
3. Plaintiffs have requested an extension of time in which to file oppositions to the

4 motions to dismiss, through and including December 16, 2009. Defendants have requested an 5 extension of time to file their replies to January 20, 2010. The parties therefore stipulate and propose 6 the following briefing and hearing dates: 7 8 9 10 11
Motions to Dismiss due: 10/29/09 Oppositions due: 12/16/09 Replies due: 1/20/10 2/17/10 Hearing date: 2/3/10, at 9:00 a.m. 4. The parties submit that good cause exists for this briefing and hearing schedule in light

12 of the varied and complex legal issues raised in the complaint, which will require consideration of 13 jurisdictional challenges per the motions to dismiss as well as determination of whether the complaint 14 is legally and/or factually sufficient to comply with federal pleading requirements. 15 IT IS SO STIPULATED.
STEVEN M. WOODSIDE, County Counsel By: /s/ Anne L. Keck Anne L. Keck Deputy County Counsel Attorneys for Defendants the County of Sonoma, SheriffCoroner William Cogbill, and Deputy Sheriff Morris Eric Salkin Dated: October 2, 2009 JOSEPH P. RUSSONIELLO United States Attorney By: /s/ Ila C. Deiss Ila C. Deiss Assistant United States Attorney Attorneys for Defendants U.S. Department of Homeland Security, Bureau of Immigration and Customs Enforcement; Special Agent-In-Charge Mark Wollman; Special Agent Mario Huelga; and Special Agent Chris Merendino

16 Dated: October 2, 2009 17 18 19 20 21 22 23 24 25 26 27 28

Joint Stipulation re Briefing and Hearing Schedule on Motions To Dismiss Second Amended Complaint; [Proposed] Order

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USDC Case No. CV-08-4220 PJH

1 Dated: October 2, 2009 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
* Dated: October 2, 2009

MICHAEL F. HERTZ Deputy Assistant Attorney General, Civil Division By: /s/ Colin Kisor Colin Kisor Trial Attorney U.S. DOJ, Office of Immigration Litigation Attorneys for Defendant U.S. Department of Homeland Security, Bureau of Immigration and Customs Enforcement LATHAM & WATKINS LLP By: /s/ Melissa N. Chan Alfred C. Pfeiffer, Jr. Melissa N. Chan Attorneys for Plaintiffs * ORDER *

PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED. 10/15/09 Date: _______________ ____________ISTRIC______________ ES D _______ T Tle Phyllis J. Hamilton C HonTrab oA United States District Court Judge

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Joint Stipulation re Briefing and Hearing Schedule on Motions To Dismiss Second Amended Complaint; [Proposed] Order

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ELECTRONIC CASE FILING ATTESTATION I, Anne L. Keck, am the ECF User whose identification and password are being used to file this JOINT STIPULATION RE BRIEFING AND HEARING SCHEDULE ON MOTIONS TO DISMISS SECOND AMENDED COMPLAINT on behalf of all parties pursuant to Civil Local

6 Rules 7-11. In compliance with General Order No. 45(X)(B), I hereby attest that the concurrence in 7 the filing of this document has been obtained from its signatories. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
By: /s/ Anne L. Keck Anne L. Keck Deputy County Counsel Dated: October 2, 2009 Sonoma County Counsel

Joint Stipulation re Briefing and Hearing Schedule on Motions To Dismiss Second Amended Complaint; [Proposed] Order

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USDC Case No. CV-08-4220 PJH