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

Filing 235

STIPULATION AND ORDER TO CONTINUE HEARING DATE ON COUNTY DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS AND FURTHER CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 1/27/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco. Joint Case Management Statement filed by 1/20/11. Motion Hearing set for 1/27/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 11/19/10. (cl, COURT STAFF) (Filed on 11/19/2010)

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ATTO R N E Y S AT LAW SA N F R A N C I S C O

LATHAM & WATKINS LLP Alfred C. Pfeiffer, Jr. (State Bar No. 120965) Hyun Jee Son (State Bar. No. 238808) Megan S. Bouchier (State Bar No. 252614) Mary Elizabeth Heard (State Bar No. 255793) Jason L. Daniels (State Bar No. 258377) Casey R. O'Connor (State Bar No. 261755) Robert Studley (State Bar No. 259818) 505 Montgomery Street, Suite 2000 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Julia Harumi Mass (State Bar No. 189649) Alan L. Schlosser (State Bar No. 49957) Amalia Greenberg Delgado (State Bar No. 269044) AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA 39 Drumm Street San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA COMMITTEE FOR IMMIGRANT RIGHTS OF SONOMA COUNTY, FRANCISCO SANCHEZLOPEZ, and CHRISTYAN SONATO-VEGA, v. Plaintiffs, CASE NO. CV-08-04220-RS STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE ON COUNTY DEFENDANTS' MOTION FOR JUDGMENT ON THE PLEADINGS AND FURTHER CASE MANAGEMENT CONFERENCE Judge: Hon. Richard Seeborg

COUNTY OF SONOMA; SHERIFF-CORONER BILL COGBILL and DEPUTY SHERIFF MORRIS ERIC SALKIN, individually and in their official capacities; U.S. DEPARTMENT OF HOMELAND SECURITY, BUREAU OF IMMIGRATION AND CUSTOMS ENFORCEMENT; SPECIAL AGENTIN-CHARGE MARK WOLLMAN, SPECIAL AGENT MARIO HUELGA and SPECIAL AGENT CHRIS MERENDINO, individually and in their official capacities; DOES 1-50; and ROES 1-50,

STIPULATION AND ORDER CASE NO. 08-4220 -RS

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ATTO R N E Y S AT LAW SA N F R A N C I S C O

inclusive, Defendants.

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STIPULATION AND ORDER CASE NO. 08-4220 -RS

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WHEREAS, the Court on October 22, 2010, ordered a further Case Management Conference to be held on January 20, 2011, at 10:00 am in Courtroom 3, 17th Floor, United States Courthouse, 450 Golden Gate Avenue, San Francisco, California, and for the parties to file a Joint Case Management Statement at least one week prior to the Conference; WHEREAS, on November 10, 2010, County Defendants the County of Sonoma, SheriffCoroner William Cogbill, and Deputy Sheriff Morris Eric Salkin ("County Defendants") filed a Motion for Judgment on the Pleadings and noticed the hearing on the motion for December 16, 2010, at 1:30 p.m.; WHEREAS, the deposition of Plaintiff Francisco Sanchez-Lopez is currently scheduled for December 16, 2010, beginning at 9:00 a.m.; WHEREAS, Plaintiffs have requested that the hearing date on County Defendants' Motion for Judgment on the Pleadings be moved to another date, so as not to occur on the same date as Plaintiff Sanchez-Lopez's deposition, and County Defendants have agreed to continue the hearing on that motion to January 27, 2011, at 1:30 p.m.; WHEREAS, to conserve the resources of the parties, they also wish to move the Case Management Conference from its current scheduling of January 20, 2011, at 10:00 a.m., to January 27, 2011, at 1:30 p.m., to occur at the same time as the hearing on County Defendants' Motion for Judgment on the Pleadings. IT IS HEREBY STIPULATED AND AGREED by and among the parties, through their respective undersigned counsel, as follows: 1. The parties respectfully request that the Court continue the hearing on County

Defendants' Motion for Judgment on the Pleadings, from its current date of December 16, 2010, to January 27, 2011, at 1:30 p.m.; and 2. The parties respectfully request that the Court continue the further Case

Management Conference, currently set for January 20, 2011, to January 27, 2011, at 1:30 p.m., with the parties to file a Joint Case Management Statement at least one week prior to the Conference.

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STIPULATION AND ORDER CASE NO. 08-4220 RS

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Authority for and concurrence in the filing of this stipulated request has been obtained from each of the signatories, pursuant to General Order 45(X)(B).

Dated: November 18, 2010

Respectfully submitted, LATHAM & WATKINS LLP Alfred C. Pfeiffer Hyun Jee Son Mary Elizabeth-Heard Megan Bouchier Jason Daniels Casey R. O'Connor Robert Studley By /s/ Hyun Jee Son Hyun Jee Son Julia Harumi Mass Alan L. Schlosser AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA Attorneys for Plaintiffs

Dated: November 18, 2010

Respectfully submitted, Stephen M. Woodside, County Counsel By /s/ Anne Keck Anne L. Keck, Deputy County Counsel Sonoma County

Attorneys for Defendants COUNTY OF SONOMA, SHERIFF-CORONER WILLIAM COGBILL, and DEPUTY SHERIFF MORRIS ERIC SALKIN

Dated: November 18, 2010

Respectfully submitted, MELINDA HAAG United States Attorney By /s/ Ila Deiss ILA DEISS
STIPULATION AND ORDER CASE NO. 08-4220 RS

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Assistant United States Attorney Attorney for Defendants SPECIAL AGENT MARIO HUELGA and SPECIAL AGENT CHRIS MERENDINO

Dated: November 18, 2010

Respectfully submitted, MICHAEL F. HERTZ Deputy Assistant Attorney General, Civil Division DAVID J. KLINE Director JOSHUA E.T. BRAUNSTEIN Assistant Director By /s/ Colin Kisor COLIN KISOR Trial Attorney

Attorneys for Defendants U.S. DEPARTMENT OF HOMELAND SECURITY, BUREAU OF IMMIGRATION AND CUSTOMS ENFORCEMENT

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STIPULATION AND ORDER CASE NO. 08-4220 RS

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ORDER IN LIGHT OF THE PARTIES' STIPULATION, IT IS HEREBY ORDERED THAT: 1. The hearing on County Defendants' Motion for Judgment on the Pleadings shall be continued from December 16, 2010, to January 27, 2011, at 1:30 p.m.; and 2. The further Case Management Conference shall be continued from January 20, 2011, to January 27, 2011, at 1:30 pm, with the parties to file a Joint Case Management Statement at least one week prior to the Conference.

11/19/10 DATED: _____________________

By:_______________________________________ THE HONORABLE RICHARD SEEBORG United States District Judge

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STIPULATION AND ORDER CASE NO. 08-4220 RS