Hatcher v. County of Alameda et al
Filing
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STIPULATION AND ORDER to Seal Confidential Exhibits Filed in Support of Plaintiff's Amended Opposition to Defendants' Motion for Summary Judgment. Signed by Judge Thelton E. Henderson on 04/11/2011. (tmi, COURT STAFF) (Filed on 4/11/2011)
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Clyde A. Thompson, SBN 72920
Benjamin A. Thompson, SBN 236590
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: 510-763-2324
Fax: 510-273-8570
Attorneys For Defendants
COUNTY OF ALAMEDA, SHERIFF GREGORY J. AHERN,
JEREMY C. LUCHA, JAMES A. RUSSELL, VICTOR GALINDO,
VICTOR CABELLO, MATTHEW NEILL, and VICENTE CLEMENTE
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John L. Burris, Esq. SBN 69888
LAW OFFICES OF JOHN L. BURRIS
7677 Oakport Street, Suite 1120
Oakland, California 94621
Tel: (510) 839-5200
Fax: (510) 839-3882
Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: 510-763-2324
Facsimile: 510-273-8570
Haapala, Thompson & Abern LLP
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Gayla B. Libet, Esq. SBN 109173
Law Offices of Gayla B. Libet
486 – 41st Street, Suite 3
Oakland, California 94609
Tel/Fax: 510-420-0324
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Attorneys For Plaintiff
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO
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BILLY J. HATCHER,
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Plaintiff,
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vs.
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COUNTY OF ALAMEDA, a governmental )
entity; GREGORY J. AHERN, in his capacity )
as Sheriff for COUNTY OF ALAMEDA;
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JEREMY C. LUCHA; JAMES A. RUSSELL; )
VICTOR GALINDO; VICTOR CABELLO; )
MATTHEW NEILL; and VICENTE
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CLEMENTE; individually and in their
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capacity as deputy sheriff’s for COUNTY OF )
ALAMEDA; and DOES 1-25, inclusive,
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Defendants.
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Case No.: C09-01650 TEH
STIPULATION OF THE PARTIES AND
ORDER THEREON TO SEAL
CONFIDENTIAL EXHIBITS FILED IN
SUPPORT OF PLAINTIFF’S AMENDED
OPPOSITION TO DEFENDANTS’
MOTION FOR SUMMARY JUDGMENT
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Hatcher v. County of Alameda, et al./Case #C09-01650 TEH
Stipulation Of The Parties And Order Thereon To Seal Confidential Exhibits Filed In Support
Of Plaintiff’s Amended Opposition To Defendants’ Motion For Summary Judgment
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Plaintiff, BILLY HATCHER, through his counsel of record Gayla B. Libet, Esq. of Law
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Offices of Gayla B. Libet, and Defendants JEREMY C. LUCHA, JAMES A. RUSSELL,
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VICTOR GALINDO, VICTOR CABELLO, and MATTHEW NEILL, through their counsel of
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record Benjamin Thompson, of Haapala, Thompson, & Abern, LLP, stipulate that the following
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exhibits filed on March 7, 2011 in support of Plaintiff’s Amended Opposition to Defendants’
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Motion for Summary Judgment are marked as confidential. These confidential documents were
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the subject of a Court Protective Order requiring they be filed under seal. To protect these
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confidential records, the parties agree that the following documents should be sealed in the court
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record.
Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: 510-763-2324
Facsimile: 510-273-8570
Documents to be sealed are:
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Haapala, Thompson & Abern LLP
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1. Exhibit 1 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary
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Judgment, consisting of a 9 page document containing copies of photographs.
2. Exhibit 3 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary
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Judgment, consisting of a 6 page group of Alameda County Sheriff’s Office documents.
3. Exhibit 4 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary
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Judgment, consisting of a 55 page Alameda County Sheriff’s Office document.
4. Exhibit 9 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary
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Judgment, consisting of a 22 page group of Alameda County Sheriff’s Office documents.
The parties agree that this stipulation does not prevent either party from presenting
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motions in limine on the above referenced materials.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: April 7, 2011
LAW OFFICES OF GAYLA B. LIBET
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By:
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*/s/ Gayla B. Libet
Gayla B. Libet, Esq.
Attorneys For Plaintiff
*Ms. Libet provided her verbal consent that
this document be electronically filed.
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/
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/
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Hatcher v. County of Alameda, et al./Case #C09-01650 TEH
Stipulation Of The Parties And Order Thereon To Seal Confidential Exhibits Filed In Support
Of Plaintiff’s Amended Opposition To Defendants’ Motion For Summary Judgment
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Dated: April 7, 2011
HAAPALA, THOMPSON & ABERN, LLP
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By:
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ORDER
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/s/ Benjamin Thompson
Benjamin A. Thompson
Attorneys For Defendants
The Court having considered the Stipulation of the parties and good cause appearing
therefore,
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IT IS HEREBY ORDERED that Exhibit 1 to Plaintiff’s Amended Opposition to
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Defendants’ Motion for Summary Judgment, consisting of a 9 page document containing copies
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documents, Exhibit 4 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary
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Judgment, consisting of a 55 page Alameda County Sheriff’s Office document, and Exhibit 9 to
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Plaintiff’s Amended Opposition to Defendants’ Motion for Summary Judgment, consisting of a
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22 page group of Alameda County Sheriff’s Office documents, shall be sealed in the Court’s
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records and permanently removed from ECF.
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Dated: 04/11/2011
ER
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R NIA
FO
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Ju
lton E. H
dge The
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RT
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n
enderso
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Honorable Thelton E. Henderson
United States Judge
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S DISTRICT
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Summary Judgment, consisting of a 6 page group of Alameda County Sheriff’s Office
UNIT
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Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: 510-763-2324
Facsimile: 510-273-8570
of photographs, Exhibit 3 to Plaintiff’s Amended Opposition to Defendants’ Motion for
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Haapala, Thompson & Abern LLP
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D IS T IC T
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OF
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Hatcher v. County of Alameda, et al./Case #C09-01650 TEH
Stipulation Of The Parties And Order Thereon To Seal Confidential Exhibits Filed In Support
Of Plaintiff’s Amended Opposition To Defendants’ Motion For Summary Judgment
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