White v. City of Oakland

Filing 72

ORDER GRANTING STIPULATION 71 . Case Management Conference set for 4/2/2014 01:00 PM in Courtroom A, 15th Floor, San Francisco. Signed by Judge Nathanael Cousins on 3/18/14. (lmh, COURT STAFF) (Filed on 3/18/2014)

1 PAUL L. REIN, Esq. (SBN 43053)
CELIA MCGUINNESS, Esq. (SBN 159420)
2 CATHERINE M. CABALO, Esq. (SBN 248198)
LAW OFFICES OF PAUL L. REIN
3 200 Lakeside Drive, Suite A
Oakland, CA 94612
4 Telephone: [phone]
Facsimile: [phone]
5 E-mail: [e-mail]
6 Attorneys for Plaintiff
DONNA WHITE
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8 BARBARA J. PARKER, City Attorney (SBN #069722)
RANDOLPH W. HALL, Chief Assistant City Atty (SBN #080142)
9 ARLENE ROSEN, Deputy City Attorney (SBN #100160)
th
10 One Frank H. Ogawa Plaza, 6 Floor
Oakland, CA 94612
11 [phone]
12 Attorneys for Defendant
CITY OF OAKLAND
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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16 DONNA WHITE,

Case No. C11-3846 NC

Plaintiff,

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Civil Rights

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STIPULATION AND [PROPOSED]
ORDER REQUESTING CASE
MANAGEMENT CONFERENCE

19 CITY OF OAKLAND,
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Defendant.
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IT IS HEREBY STIPULATED BETWEEN THE PARTIES, BY AND THROUGH THEIR

23 RESPECTIVE ATTORNEYS OF RECORD, AS FOLLOWS:
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Whereas,
1. The hearing for plaintiff’s motion for summary judgment is scheduled for April 2,
2014;
2. The pretrial conference statement is due April 11, the pretrial conference is set for
April 23, and trial is scheduled for May 12, 2014;
STIPULATION AND [PROPOSED] ORDER REQUESTING CASE MANAGEMENT CONFERENCE
Case No. C11-3846 NC

3. The parties have re-opened settlement negotiations and Howard Herman, ADR

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Director, has agreed to facilitate them;

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4. The parties believe that they are close to settlement;

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5. The expenditure of time and resources to prepare for trial would inhibit, rather than
encourage, settlement;

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Therefore, the parties stipulate and request:

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1. The Court schedule a Case Management Conference to discuss extending the

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litigation schedule, providing time for the parties to negotiate and allowing

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them to receive and digest the Court’s ruling on Plaintiff’s motion for summary
judgment before trial.

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2. The Court schedule the CMC concurrently with the hearing on Plaintiff’s

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Motion for Partial Summary Judgment at 1:00 p.m. on Wednesday, April 2,

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2014.

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Respectfully submitted,

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Dated: March 18, 2014

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/s/Celia McGuinness
By CELIA MCGUINNESS
Attorneys for Plaintiff
DONNA WHITE

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Dated: March 18, 2014

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OFFICE OF THE CITY ATTORNEY
OF OAKLAND
/s/ Arlene M. Rosen
By ARLENE M. ROSEN
Attorneys for Defendant
CITY OF OAKLAND

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LAW OFFICES OF PAUL L. REIN

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STIPULATION AND [PROPOSED] ORDER REQUESTING CASE MANAGEMENT CONFERENCE
Case No. C11-03846 NC

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GOOD CAUSE BEING SHOWN, a further case management conference will be set at 1:00
p.m. on Wednesday, April 2, 2014.

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MAGISTRATE JUDGE NATHANAEL COUSINS

UNIT
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5 Dated: March ___, 2014
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GRAN

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ORDER

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M. Cousin

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thanael
Judge Na

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STIPULATION AND [PROPOSED] ORDER REQUESTING CASE MANAGEMENT CONFERENCE
Case No. C11-03846 NC

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