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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Clyde A. Thompson, SBN 72920
Benjamin A. Thompson, SBN 236590
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: [phone]
Fax: [phone]
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: [phone]
Fax: [phone]

Attorneys At Law
Park Plaza Building
1939 Harrison St., Suite 800
Oakland, California 94612
Telephone: [phone]
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: [phone]

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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;
)
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,
)
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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: [phone]
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

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Ju

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Honorable Thelton E. Henderson
United States Judge

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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: [phone]
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