Frayer v. County of Alameda et al

Filing 28

ORDER to continue Settlement Conference and CMC re 27 Stipulation filed by Katherine More, Thomas Nolan, County of Alameda Further Case Management Conference set for 8/19/2011 08:30 AM in Courtroom 8, 19th Floor, San Francisco.. Signed by Judge Charles R. Breyer on 5/4/2011. (beS, COURT STAFF) (Filed on 5/4/2011)

Case3:10-cv-04095-CRB Document27

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Filed04/28/11 Page1 of 3

Rebecca S. Widen, SBN 219207
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: [phone]
Fax: [phone]

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Attorneys For Defendants
COUNTY OF ALAMEDA, KATHERINE MOORE,
and THOMAS NOLAN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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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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AARON FRAYER, individually and as Next )
)
Friend of A.F., a minor,
)
)
Plaintiffs,
)
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vs.
)
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COUNTY OF ALAMEDA; KATHERINE
)
MORE, individually and in her official
capacity as social worker for Alameda County )
)
Department of Social Services; THOMAS
)
NOLAN, individually and in his official
capacity as social worker for Alameda County )
)
Department of Social Services; CITY OF
OAKLAND; JAMES MOORE, individually )
and in his official capacity as a police officer )
)
for the City of Oakland; D. MING,
)
individually and in his official capacity as
sergeant for the City of Oakland; and DOES 1 )
)
through 20,
)
)
Defendants.
)

Case No.: C10-4095 CRB (BZ)
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE SETTLEMENT
CONFERENCE AND CASE
MANAGEMENT CONFERENCE

The parties hereto, by and through their undersigned counsel, jointly request that the
settlement conference scheduled for May 12, 2011, at 9:00 a.m., as well as the case management
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conference scheduled for May 13, 2011, at 8:30 a.m., be continued for a period of 90 days.
The reason for the requested continuance is that the parties have not yet completed the

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initial discovery necessary to ensure a meaningful and productive settlement conference.

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Specifically, the parties require additional time to identify and obtain the discoverable

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Frayer v. County of Alameda, et al./Case #C10-4095 CRB (BZ)
Stipulation And [Proposed] Order To Continue Settlement Conference And Case Management Conference

Case3:10-cv-04095-CRB Document27

Filed04/28/11 Page2 of 3

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documents contained in the minor plaintiff’s juvenile court records through the Welfare and

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Institutions Code section 827 process, and thereafter take some initial depositions. The parties

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are currently working on the form of a proposed order for disclosure of juvenile court records

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and anticipate filing same within the next 10 days.
IT IS SO STIPULATED.

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Dated: April 28, 2011

LAW OFFICES OF DAVID J. BEAUVAIS

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By:

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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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Dated: April 28, 2011

*/s/ David J. Beauvais
David J. Beauvais
Attorneys For Plaintiffs
*Mr. Beauvais provided his verbal consent that this
document be electronically filed.

HAAPALA, THOMPSON & ABERN, LLP

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By:

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Dated: April 28, 2011

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/s/ Rebecca S. Widen
Rebecca S. Widen
Attorneys For Defendants
COUNTY OF ALAMEDA, KATHERINE
MOORE and THOMAS NOLAN

JOHN A. RUSSO, City Attorney
RANDOLPH W. HALL, Chief Assistant City Attorney
WILLIAM E. SIMMONS, Supervising Trial Attorney
CAROLYN O. TSAI, Deputy City Attorney

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By:

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/*/ Carolyn O. Tsai
Carolyn O. Tsai
Attorneys for Defendants
CITY OF OAKLAND, JAMES MOORE and
D. MING
*Ms. Tsai provided her verbal consent that this
document be electronically filed.
ORDER

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Pursuant to stipulation and for good cause shown, it is SO ORDERED. The parties’ case

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management conference is hereby rescheduled to August 19, 2011, at 8:30 a.m. The parties

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shall contact Magistrate Judge Bernard Zimmerman’s chambers to reschedule the settlement

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/

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Frayer v. County of Alameda, et al./Case #C10-4095 CRB (BZ)
Stipulation And [Proposed] Order To Continue Settlement Conference And Case Management Conference

Case3:10-cv-04095-CRB Document27

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conference for an available date prior to August 19, 2011.

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Dated: May 4, 2011

. Breyer

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FO

harles R
Judge C

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R NIA

Honorable Charles R. SO ORDERED
Breyer
IT IS
United States District Judge

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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

Haapala, Thompson & Abern LLP

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Frayer v. County of Alameda, et al./Case #C10-4095 CRB (BZ)
Stipulation And [Proposed] Order To Continue Settlement Conference And Case Management Conference