Rivers v. County of Marin et al

Filing 51

STIPULATION AND ORDER CONTINUING CMC re 50 Stipulation filed by Simone Rivers. Signed by Judge Edward M. Chen on 7/13/10. (bpf, COURT STAFF) (Filed on 7/13/2010)

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PATRICK K. FAULKNER, COUNTY COUNSEL Stephen Raab, SBN 180939 3501 Civic Center Drive, Room 275 San Rafael, CA 94903 Tel.: [phone], Fax: [phone] Attorney(s) for Defendants County of Marin William Burke, Mike Daly, and Terri Hampton David M. Poore, SBN 192541 KAHN BROWN & POORE LLP 30 Fifth Street, Second Floor Petaluma, California 94952 Telephone: [phone] Facsimile: [phone] [e-mail] Attorneys for Plaintiff SIMONE RIVERS UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

SIMONE RIVERS; Plaintiff, v. COUNTY OF MARIN; WILLIAM BURKE MICHAEL DALY; TERRI HAMPTON; and DOES 1 through 50, Defendants.

Case No.: USDC 09 1614 EMC STIPULATION AND PROPOSED ORDER TO FILE AND SERVE FIRST AMENDED COMPLAINT RESETTING CMC

IT IS HEREBY STIPULATED by and between the parties to continue the Case Management Conference, which is presently set for July 14, 2010, at 2:30 p.m., for 30 days to allow the parties to finalize the settlement. There is good cause in which to grant this request as the Marin County Board of Supervisors has now approved the settlement and the parties are working on finalizing the further written settlement agreement and release. This case is slightly more complicated that other cases in

STIPULATION AND PROPOSED ORDER TO CONTINUE THE CMC RIVERS v. COUNTY OF MARIN ET AL, CASE NO. C09-1614 EMC

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which the consideration is monetary. This case involves complex issues of retirement, COBRA benefits, and other non-monetary relief. .

SO STIPULATED.

Dated: ___07/12/10____________

KAHN, BROWN & POORE LLP BY:______/s/ David M. Poore________ DAVID POORE Attorney for Plaintiff

Dated: ___07/12/10____________

PATRICK K. FAULKNER MARIN COUNTY COUNSEL BY:____/s/ Stephen Raab_____________ STEPHEN RAAB Attorney for Defendant County of Marin

PROPOSED ORDER

THE COURT HEREBY ORDERS AS FOLLOWS: The parties' stipulation and proposed order to continue the CMC is approved and Granted. The parties 2:30 p.m. are ordered to appear on August 11 2010, at ________, for a further CMC to confirm settlement. __,
An updated joint cmc statement shall be filed by August 4, 2010.

DATED:

7/13/10 _______________________

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STIPULATION AND PROPOSED ORDER TO FILE FIRST AMENDED COMPLAINT E USDC 09 1614 EMC RIVERS v. COUNTY OF MARIN ET AL, CASE NO.R C

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HON. EDWARD M. CHEN U.S. MAGISTRATE JUDGE DERED

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