Hatcher v. County of Alameda et al

Filing 51

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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1 2 3 4 5 6 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 7 8 9 10 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 11 12 14 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 15 Attorneys For Plaintiff 13 16 UNITED STATES DISTRICT COURT 17 NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO 18 19 20 21 22 23 24 25 26 27 BILLY J. HATCHER, ) ) Plaintiff, ) ) vs. ) ) COUNTY OF ALAMEDA, a governmental ) entity; GREGORY J. AHERN, in his capacity ) as Sheriff for COUNTY OF ALAMEDA; ) JEREMY C. LUCHA; JAMES A. RUSSELL; ) VICTOR GALINDO; VICTOR CABELLO; ) MATTHEW NEILL; and VICENTE ) CLEMENTE; individually and in their ) capacity as deputy sheriff’s for COUNTY OF ) ALAMEDA; and DOES 1-25, inclusive, ) ) Defendants. ) ) / 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 28 1 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 1 Plaintiff, BILLY HATCHER, through his counsel of record Gayla B. Libet, Esq. of Law 2 Offices of Gayla B. Libet, and Defendants JEREMY C. LUCHA, JAMES A. RUSSELL, 3 VICTOR GALINDO, VICTOR CABELLO, and MATTHEW NEILL, through their counsel of 4 record Benjamin Thompson, of Haapala, Thompson, & Abern, LLP, stipulate that the following 5 exhibits filed on March 7, 2011 in support of Plaintiff’s Amended Opposition to Defendants’ 6 Motion for Summary Judgment are marked as confidential. These confidential documents were 7 the subject of a Court Protective Order requiring they be filed under seal. To protect these 8 confidential records, the parties agree that the following documents should be sealed in the court 9 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: 11 Haapala, Thompson & Abern LLP 10 1. Exhibit 1 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary 12 Judgment, consisting of a 9 page document containing copies of photographs. 2. Exhibit 3 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary 13 14 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 15 16 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 17 18 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 19 20 motions in limine on the above referenced materials. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 21 22 Dated: April 7, 2011 LAW OFFICES OF GAYLA B. LIBET 23 By: 24 25 */s/ Gayla B. Libet Gayla B. Libet, Esq. Attorneys For Plaintiff *Ms. Libet provided her verbal consent that this document be electronically filed. 26 27 / 28 / 2 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 1 Dated: April 7, 2011 HAAPALA, THOMPSON & ABERN, LLP 2 3 By: 4 ORDER 5 6 7 /s/ Benjamin Thompson Benjamin A. Thompson Attorneys For Defendants The Court having considered the Stipulation of the parties and good cause appearing therefore, 8 IT IS HEREBY ORDERED that Exhibit 1 to Plaintiff’s Amended Opposition to 9 Defendants’ Motion for Summary Judgment, consisting of a 9 page document containing copies 12 documents, Exhibit 4 to Plaintiff’s Amended Opposition to Defendants’ Motion for Summary 13 Judgment, consisting of a 55 page Alameda County Sheriff’s Office document, and Exhibit 9 to 14 Plaintiff’s Amended Opposition to Defendants’ Motion for Summary Judgment, consisting of a 15 22 page group of Alameda County Sheriff’s Office documents, shall be sealed in the Court’s 16 records and permanently removed from ECF. 17 Dated: 04/11/2011 ER 23 R NIA FO LI Ju lton E. H dge The H 22 RT 21 n enderso NO 20 Honorable Thelton E. Henderson United States Judge A 19 S DISTRICT TE C TA RT U O 18 S Summary Judgment, consisting of a 6 page group of Alameda County Sheriff’s Office UNIT ED 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 11 Haapala, Thompson & Abern LLP 10 N D IS T IC T R OF C 24 25 26 27 28 3 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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