Baires et al v. United States of America et al

Filing 196

ORDER Resetting Deadlines as to 192 Amended MOTION for Summary Judgment United States' Amended Notice of Motions and Motions For Judgment On The Pleadings on Plaintiffs' Third Amended Complaint Or, In The Alternative, For Summary Judgment. Responses due by 6/17/2013 and shall have up to 40 pages. The U S will have up to 20 pages for its reply due after the settlement conference currently scheduled for 6/20/2013. Signed by Judge Charles R. Breyer on 6/11/2013. (beS, COURT STAFF) (Filed on 6/11/2013)

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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Steven M. Kohn (SBN 61758)
Email: [e-mail]
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
* Additional Attorneys for Plaintiffs on Following Page
MELINDA HAAG (SBN 132612)
United States Attorney
ABRAHAM A. SIMMONS (SBN 14600)
Email: [e-mail]
Assistant United States Attorney
450 Golden Gate Avenue, 9th Floor
San Francisco, California 94102-3495
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant UNITED STATES OF
AMERICA
* Additional Attorneys for Defendant United States of
America, et al. on Following Page
THERESA A. GOLDNER, COUNTY COUNSEL
COUNTY OF KERN, STATE OF CALIFORNIA
By Marshall Scott Fontes Deputy (SBN 139567)
Email: [e-mail]
Administrative Center
1115 Truxtun Avenue, Fourth Floor
Bakersfield, California 93301
Telephone: [phone]
Attorneys for Defendants COUNTY OF KERN, et al.
* Additional Attorneys for Defendant County of Kern,
et al. on Following Page

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DORA BAIRES, et al.,

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No.: C 09-05171 CRB

Plaintiffs,

STIPULATION AND ORDER

vs.
THE UNITED STATES OF AMERICA; et al.,

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Honorable Charles R. Breyer

Defendants.

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C 09-05171 CRB

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STIPULATION AND [PROPOSED] ORDER

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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ADDITIONAL COUNSEL FOR PLAINTIFFS
Jayne E. Fleming (SBN 209026)
Email: [e-mail]
Benjamin D. Spohn (SBN266746)
Email: [e-mail]
Daniel B. Ruby (SBN 281196)
Email: [e-mail]
REED SMITH LLP
101 Second Street, Suite 1800
San Francisco, CA 94105-3659
Telephone:
[phone]
Facsimile:
[phone]
ADDITIONAL COUNSEL FOR FEDERAL DEFENDANTS
Alex Tse (SBN 152348)
Chief, Civil Division
450 Golden Gate Avenue, 9th Floor
San Francisco, California 94102-3495
ADDITIONAL COUNSEL FOR DEFENDANTS COUNTY OF KERN, ET AL.
Robert K. Lawrence, SBN 83600
Email: [e-mail]
Elizabeth K. Ryan, SBN 117369
Email: [e-mail]
Robyn D. Roberts, SBN 136208
Email: [e-mail]
BJORK LAWRENCE
1850 Mt. Diablo Boulevard, Suite 120
Walnut Creek, California 94596
Telephone:
[phone]
Facsimile:
[phone]

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No. C 09-05171 CRB

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STIPULATION AND [PROPOSED] ORDER

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Counsel for Plaintiffs, Defendant United States and Defendant Brian Myrick have met and
conferred regarding the need for a revised briefing schedule for a motion for summary judgment that
was filed by Defendant United States on Friday May 24, 2013, seeking dismissal of Plaintiffs’
claims under the FTCA. Because the motion was filed nearly 30 days beyond the date initially
agreed by the parties, the parties have stipulated as follows:

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1.

Plaintiffs will file their opposition to the motion for summary judgment no later than

June 17, 2013, and plaintiffs shall have up to 40 pages in their opposition. The United States will
have up to 20 pages for its reply.

REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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2.

The due date for the reply brief of the United States will be after the settlement

conference with Magistrate Judge La Porte which is now scheduled for June 20, 2013.

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3.

Defendant Myrick may file his motion for summary judgment, if any, in accordance

with the previously-established deadlines set by the court or earlier, if he chooses to do so.

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IT IS SO STIPULATED.

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DATED: May 31, 2013.
REED SMITH LLP

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By

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/s/ Steven M. Kohn
Steven M. Kohn
Attorneys for Dora Baires, individually, and on
behalf of the estate of Juan Carlos Baires; and
Teofilo Miranda

DATED: May 31, 2013.

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MELINDA HAAG, United States Attorney

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By

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No. C 09-05171 CRB

/s/ Abraham A. Simmons
Abraham A. Simmons, Assistant U.S. Attorney
Attorneys for Federal Defendants
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STIPULATION AND [PROPOSED] ORDER

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DATED: May 31, 2013.
THERESA A. GOLDNER, County Counsel

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By

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/s/ Marshall Scott Fontes
Marshall Scott Fontes, Deputy
(as authorized on February 21, 2013)
Attorneys for Defendant County of Kern, et al.

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DATED: May 31, 2013.
BJORK LAWRENCE

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/s/ Robert Lawrence
Robert Lawrence
Attorneys for Defendant County of Kern, et al.

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IT IS SO ORDERED.

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DATED: June 11, 2013.

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The Honorable Charles R.ERED
Breyer
United StatesS SO ORD Judge
District Court
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STIPULATION AND [PROPOSED] ORDER

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