Campbell et al v. City of Oakland et al

Filing 64

STIPULATION AND ORDER RE 63 FOR AN ORDER EXTENDING DATE FOR AMENDMENT OF PLEADINGS. Signed by Judge Richard Seeborg on 6/11/12. (cl, COURT STAFF) (Filed on 6/11/2012)

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Alan L. Schlosser (#49957)
Michael T. Risher (#191627)
Linda Lye (#215584)
ACLU Foundation of Northern California
39 Drumm Street
San Francisco, CA 94111
[phone]; [phone]
[e-mail],
[e-mail], [e-mail]
Attorneys for Plaintiffs Kerie Campbell,
Marcus Kryshka, and ACLU-NC

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RACHEL LEDERMAN, SBN 130192
Rachel Lederman & Alexsis C. Beach,
Attorneys at Law
558 Capp Street
San Francisco, CA 94110
[phone]; fax [phone]
[e-mail]

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and additional counsel listed on pleadings
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Attorneys for plaintiffs Timothy Scott
Campbell et al.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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TIMOTHY SCOTT
CAMPBELL, et al.,

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Plaintiffs,

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vs.

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CITY OF OAKLAND, et al.

No. CV11-05498 RS
STIPULATED REQUEST FOR AN ORDER
EXTENDING DATE FOR AMENDMENT OF
PLEADINGS, DECLARATION AND
PROPOSED ORDER
Complaint Filed: Nov. 14, 2011
Trial Date: May 28, 2013

Defendants.

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Whereas, this court set a deadline of June 30, 2012, for the parties to complete all
amendments to the pleadings;
STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS
CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS
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Whereas all current parties agree that it would be most efficient to join all parties

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in one action, and additional time is needed to do so as more fully set forth in the attached

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declaration of plaintiffs’ counsel;

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THEREFORE, the parties through their respective counsel jointly request that the
court extend the date for amendment of pleadings to August 1, 2012.
It is so stipulated.
Dated: June 8, 2012

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/S/
Rachel Lederman
Attorneys for plaintiffs Scott Campbell, et al.

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/S/
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Linda Lye
Attorneys for plaintiffs ACLU-NC, et al.

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/S/

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William Simmons, Supervising City Attorney
Attorney for defendants

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SIGNATURE ATTESTATION
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I am the ECF User whose ID and Password are being used to file
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this stipulated request. In compliance with General Order 45, X.B., I hereby attest that
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Ms. Lye and Mr. Simmons have concurred in this filing.
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Dated: June 8, 2012

/S/
Rachel Lederman

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STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS
CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS
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DECLARATION OF RACHEL LEDERMAN
I am an attorney admitted to practice before this court and the attorney of record
for plaintiffs Timothy Scott Campbell, Mark McKinnie, and Michael Siegel.
As discussed at the Case Management Conference, plaintiffs’ counsel represent

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approximately fifteen people who were injured during the two demonstrations at issue in

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this case. Because this matter was originally filed only two weeks after these events, in

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conjunction with an application for a Temporary Restraining Order, all plaintiffs and

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defendants were not named at that time. Each of the two events at issue involved a

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mutual aid operation by a large number of law enforcement agencies. Counsel have been

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working diligently to investigate and obtain discovery in order to ascertain the responsible

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parties and avoid unnecessarily naming government entity or individual defendants who

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do not bear responsibility. Due to the large volume of evidence involved, additional time

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is required to complete this process and prepare the amended pleadings.

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I declare under penalty of perjury that the foregoing is true and correct. Executed
this June 8, 2012, at San Francisco, California.

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/S/
Rachel Lederman

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STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS
CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS
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[PROPOSED] ORDER
Pursuant to stipulation, the court sets the following deadline for completion of
amendment of pleadings: August 1, 2012.

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6/11/12
Dated: _________________
____________________________
RICHARD SEEBORG
United States District Judge

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STIP REQU FOR ORDER EXTENDING DATE FOR AMENDMT OF PLEADINGS
CAMPBELL, ET AL. V. CITY OF OAKLAND, CASE NO. CV11-05498 RS
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