City and County of San Francisco et al v. United States Postal Service et al

Filing 188

STIPULATION AND ORDER REGARDING ACCELERATED BRIEFING SCHEDULE ON DEFENDANT'S MOTION TO MODIFY SCHEDULING ORDER AND PLAINTIFFS' MOTION FOR A STAY. Signed by Judge Richard Seeborg on 6/22/11. (cl, COURT STAFF) (Filed on 6/22/2011)

*E-Filed 6/22/11*

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DENNIS J. HERRERA, City Attorney (State Bar No. 139669)
DANNY CHOU, Chief of Complex and Special Litigation (State Bar No. 180240)
SHERRI SOKELAND KAISER (State Bar No. 197986)
TARA M. STEELEY (State Bar No. 231775)
Deputy City Attorneys
CITY ATTORNEY’S OFFICE
City Hall, Room 234
1 Dr. Carlton B. Goodlett Place
San Francisco, California 94102-4682
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]; [e-mail]
Attorneys for Plaintiff CITY AND COUNTY OF SAN FRANCISCO
MELINDA HAAG
United States Attorney
JOANN M. SWANSON
Assistant United States Attorney
Chief, Civil Division
JONATHAN U. LEE (CSBN 148792)
THOMAS R. GREEN (CSBN 203480)
VICTORIA R. CARRADERO (CSBN 217885)
Assistant United States Attorneys
Northern District of California
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Defendant UNITED STATES OF AMERICA
Additional Counsel Listed on Signature Page

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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CITY AND COUNTY OF SAN
FRANCISCO, CENTRAL CITY SRO
COLLABORATIVE, SAN FRANCISCO
TENANTS UNION, and HOUSING RIGHTS
COMMITTEE OF SAN FRANCISCO

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Plaintiffs,

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Case No. C09-1964 RS
STIPULATION AND [PROPOSED] ORDER
REGARDING ACCELERATED BRIEFING
SCHEDULE ON DEFENDANT’S MOTION TO
MODIFY SCHEDULING ORDER AND
PLAINTIFFS’ MOTION FOR A STAY

vs.

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UNITED STATES POSTAL SERVICE,
Defendant.

STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS

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BY AND THROUGH THEIR COUNSEL OF RECORD, THE PARTIES STIPULATE AS
FOLLOWS:
WHEREAS, the Postal Service intends to file a motion to modify the scheduling
order to continue the deadline to file dispositive motions (currently set for June 30) for four
weeks until July 28 so that all discovery disputes are resolved and all expert discovery is
completed prior to the filing of dispositive motions. The Postal Service does not seek a
continuance of the trial date. Plaintiffs do not agree to a modification of the scheduling order.
WHEREAS, on May 18, 2011, Plaintiffs filed a complaint before the Postal
Regulatory Commission and intend to file a motion to stay this district court action. The Postal
Service does not agree to a stay of this action.
WHEREAS, the parties have agreed to a shortened briefing schedule on both
issues. The schedule is as follows:
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All parties will file their respective motions by today at 4:00.

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All parties will file their oppositions by tomorrow at 4:00.

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The parties are available to appear before the Court on Friday, June 24, if
the Court wishes to hear oral argument.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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-3STIPULATION AND PROPOSED ORDER, CASE NO. 09-1964 RS

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DATED:

June 22, 2011
MELINDA HAAG
United States Attorney

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By:
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Dated:

June 22, 2011

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COVINGTON & BURLING LLP
By: __/s/ Kelly P. Finley_________________
MICHAEL M. MARKMAN
KELLY P. FINLEY
JOSHUA D. HURWIT

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Attorneys for Plaintiffs
CITY AND COUNTY OF SAN FRANCISCO,
CENTRAL CITY SRO COLLABORATIVE, SAN
FRANCISCO TENANTS UNION, and HOUSING
RIGHTS COMMITTEE OF SAN FRANCISCO
COUNTY

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/s/ Jonathan U. Lee
JONATHAN U. LEE
Assistant U.S. Attorney
COUNSEL FOR THE UNITED STATES OF
AMERICA

Dated:

June 22, 2011

DENNIS J. HERRARA, CITY ATTORNEY

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By:
/s/ Sherri S. Kaiser_______________
SHERRI SOKELAND KAISER
TARA M. STEELEY

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Attorneys for Plaintiff
CITY AND COUNTY OF SAN FRANCISCO

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Defendant’s motion to modify the scheduling order is due today at 4:00 p.m. Plaintiffs’

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motion for a stay is due today at 4:00 p.m. The parties’ Oppositions to each other’s respective

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motions are due tomorrow by 4:00. The Court will notify the parties if oral argument is

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necessary.

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-4STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS

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DATED:

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June ___, 2011
HON. RICHARD SEEBORG
United States District Court Judge

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-5STIPULATION AND PROPOSED ORDER, CASE NO. CV 09-1964 RS