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

Filing 254

STIPULATION AND ORDER RE 253 TO FURTHER EXTEND TEMPORARY STAY OF ACTION AND CONTINUE CASE MANAGEMENT CONFERENCE. Further Case Management Conference set for 5/26/2011 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 3/9/11. (cl, COURT STAFF) (Filed on 3/9/2011)

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

Doc. 254

*E-Filed 3/9/11*

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 BRUCE D. GOLDSTEIN, State Bar No. 135970 7 ANNE L. KECK, State Bar No. 136315 8 County of Sonoma
Deputy County Counsel 575 Administration Drive, Room 105-A Telephone: [phone] E-mail: [e-mail] Attorneys for Defendants County Counsel

9 Santa Rosa, California 95403-2815 10 Facsimile: [phone] 11

12 County of Sonoma, Sheriff-Coroner William 13 14 15 16 17 18 COMMITTEE FOR IMMIGRANT RIGHTS 19 20 21 22 23 24
v. COUNTY OF SONOMA, et al., Defendants. / The parties herein, through their respective counsel of record, hereby agree and stipulate as OF SONOMA COUNTY, et al., Plaintiffs, JOINT STIPULATION TO FURTHER EXTEND TEMPORARY STAY OF ACTION AND CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER No. CV-08-4220-RS Cogbill, Deputy Sheriff Morris Eric Salkin UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

25 follows. 26 27
1. RECITALS Pursuant to a stipulation of the parties, this Court entered an Order on December 22,

28 2010, vacating all dates previously ordered by the Court in this action (with the exception of the Case

Joint Stipulation to Further Extend Temporary Stay of Action and Continue CMC; [Proposed] Order

USDC Case No. CV-08-4220 RS Dockets.Justia.com

1 Management Conference date) and staying this action through February 10, 2011. (Dkt. No. 247.) 2 For the purposes of this stipulation, this stay shall be referred to herein as the "Temporary Stay." In 3 the Temporary Stay Order, the Court also continued the Case Management Conference to March 17, 4 2011, at 10:00 a.m. (Id.). The parties' purpose in requesting the stay was to permit them to pursue 5 further settlement discussions without the necessity of attending to other litigation demands. 6
2. On February 10, 2011, this Court approved the parties' stipulation to extend the

7 Temporary Stay through March 16, 2011, with identified exceptions, for the purpose of permitting 8 them to continue their settlement discussions. (Dkt. No. 251.) Per that Order, the Case Management 9 Conference date remained set for March 17, 2011. 10
3. On March 4, 2011, the parties participated in a further settlement conference before

11 Magistrate Judge Chen. Discussions and issues raised at that conference require further consideration 12 by the parties as part of the settlement process. Magistrate Judge Chen has indicated that he is open to 13 assisting the parties further with their ongoing settlement process if needed. 14
4. Accordingly, the parties believe that it is in their and the Court's best interests to

15 further extend the Temporary Stay through April 15, 2011, to permit them to continue their settlement 16 discussions unimpeded by other litigation demands. To this end, the parties also seek a continuance 17 of the Case Management Conference, currently set for March 17, 2011, to May 26, 2011, or such 18 other date that is convenient for the Court. 19 20
5. STIPULATION Based on the foregoing, the parties stipulate and request entry of an order extending

21 the Temporary Stay of this action through and including April 15, 2011, with the exception that 22 Magistrate Judge Chen may enter orders regarding the settlement process during the period of the 23 stay. 24
6. The parties further stipulate and request entry of an order continuing the Case

25 Management Conference currently set for March 17, 2011, to May 26, 2011, at 10:00 a.m., or such 26 other date and time as are convenient for the Court. The Joint Supplemental Case Management 27 Statement is requested to be due one week prior to the conference. 28 IT IS SO STIPULATED:

Joint Stipulation to Further Extend Temporary Stay of Action and Continue CMC; [Proposed] Order

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USDC Case No. CV-08-4220 RS

1 2 3 Dated: March 9, 2011 4 5 6 7 8 9 Dated: March 9, 2011 10 11 12 13 14 15 Dated: March 9, 2011 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 9, 2011

Respectfully submitted,

BRUCE D. GOLDSTEIN County Counsel, County of Sonoma By: /s/ Anne L. Keck Anne L. Keck Deputy County Counsel Attorneys for Defendants the County of Sonoma, Sheriff-Coroner William Cogbill, and Deputy Sheriff Morris Eric Salkin MELINDA HAAG 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 Mario Huelga; and Special Agent Chris Merendino 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/ Robert Studley Alfred C. Pfeiffer, Jr. Robert Studley Julia Harumi Mass Alan L. Schlosser AMERICAN CIVIL LIBERTIES UNION FOUNDATION OF NORTHERN CALIFORNIA Attorneys for Plaintiffs

Joint Stipulation to Further Extend Temporary Stay of Action and Continue CMC; [Proposed] Order

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USDC Case No. CV-08-4220 RS

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[PROPOSED] ORDER Pursuant to the foregoing stipulation, and with good cause appearing, it is hereby

3 ordered as follows: 4 5 6 7 8 9 10 b. a. This action shall remain temporarily stayed through and including April 15, 2011, with the exception that Magistrate Judge Chen may enter orders regarding the settlement process during the period of the stay. The Case Management Conference currently set for March 17, 2011, shall be continued to May 26, 2011, at 10:00 a.m., and the Joint Supplemental Case Management Conference Statement is due to be filed one week prior. IT IS SO ORDERED. _________________________________ Honorable Richard Seeborg United States District Court Judge

11 Date: _______________ 3/9/11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Joint Stipulation to Further Extend Temporary Stay of Action and Continue CMC; [Proposed] Order

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USDC Case No. CV-08-4220 RS