Conley v. City and County of San Francisco et al
Filing
155
ORDER re 144 Stipulation Regarding Evidence filed by Prentice Earl Sanders, City and County of San Francisco. Signed by Judge Joseph C. Spero on 6/19/13. (klhS, COURT STAFF) (Filed on 6/20/2013)
1
2
3
4
5
6
7
8
9
10
11
12
13
DENNIS J. HERRERA, City Attorney
CHERYL ADAMS, State Bar #164194
Chief Trial Deputy
PETER J. KEITH, State Bar #206482
VINCE CHHABRIA, State Bar # 208557
JOSHUA S. WHITE, State Bar #237223
ELIZABETH PEDERSON, State Bar #288184
Deputy City Attorneys
1390 Market Street, 6th Floor
San Francisco, California 94102-5408
Telephone:
(415) 554-3908 [Keith]
Telephone: (415) 554-4674 [Chhabria]
Telephone:
(415) 554-4259 [White]
Telephone:
(415) 554-3862 [Pederson]
Facsimile:
(415) 554-3837
Email:
peter.keith@sfgov.org
Email:
vince.chhabria@sfgov.org
Email:
joshua.white@sfgov.org
Email:
elizabeth.pederson@sfgov.org
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO
and PRENTICE EARL SANDERS
19
KEKER & VAN NEST LLP
DANIEL PURCELL, #191424
dpurcell@kvn.com
ERIC H. MACMICHAEL, #231697
emacmichael@kvn.com
REBEKAH L. PUNAK, #248588
rpunak@kvn.com
H. SAVALA NOLAN, #284212
snolan@kvn.com
633 Battery Street San Francisco, CA 94111-1809
Telephone: 415 391 5400
Facsimile: 415 397 7188
20
Attorneys for Plaintiff CARAMAD CONLEY
14
15
16
17
18
21
UNITED STATES DISTRICT COURT
22
NORTHERN DISTRICT OF CALIFORNIA
23
CARAMAD CONLEY,
24
Plaintiff,
25
vs.
26
27
Case No. C12-00454 JCS
STIPULATIONS REGARDING EVIDENCE
CITY AND COUNTY OF SAN FRANCISCO
and PRENTICE EARL SANDERS,
Defendants.
28
STIPULATIONS REGARDING EVIDENCE
CV12-00454 JCS
1
n:\lit\li2012\070571\00848291.doc
1
WHEREAS, the parties have met and conferred in an effort to streamline discovery and the
2
presentation of evidence at summary judgment and/or trial in the present action, and the parties have
3
identified documents the authenticity of which is not disputed,
4
THEREFORE, the parties stipulate as follows:
5
1.
All documents listed in Exhibit A are authentic. All documents listed in Exhibit A that
6
were prepared by public employees, except for pleadings, meet the requirements of Federal Rule of
7
Evidence 803(6).
8
2.
9
All court records, pleadings, and transcripts in the proceedings People v. Paul Green,
S.F. Superior Court Case No. 140-303 and People v. Caramad Conley, S.F. Superior Court Case No.
10
153-756, are judicially noticeable as evidence of what occurred during those proceedings under
11
Federal Rule of Evidence 201. The parties are not stipulating or agreeing to the truth of any statement
12
contained within such court records, pleadings or transcripts, and reserve all arguments for and against
13
admissibility for the truth of the matters stated.
14
15
16
3.
Copies of court records, pleadings, and transcripts shall be treated as authentic without
any need for certification.
4.
For all such documents listed above, the parties further stipulate that neither party need
17
produce a qualified witness to testify or declare as to the identity, time, and mode of preparation of the
18
documents. By entering this stipulation, neither side waives its right to object to the admissibility of
19
any particular document listed above or its contents on other grounds. This includes but is not limited
20
to the following: the document contains hearsay within hearsay or the document and its contents are
21
not relevant to the issues to be tried in the case.
22
5.
All depositions taken in the proceeding Caramad Conley v. Mike Knowles, San
23
Francisco Superior Court Writ No. 5861, and all testimony given in the evidentiary hearing in that
24
proceeding, shall be usable in the present action as if they were depositions given in the present action.
25
//
26
//
27
//
28
STIPULATIONS REGARDING EVIDENCE
CV12-00454 JCS
2
n:\lit\li2012\070571\00848291.doc
1
2
3
4
6.
Notwithstanding any of the foregoing, defendants do not stipulate to the authenticity of
the document entitled "Declaration of Clifford Polk" dated December 13, 2005.
IT IS SO STIPULATED.
Dated: June 18, 2013
5
DENNIS J. HERRERA
City Attorney
6
By:
7
8
/s/
PETER J. KEITH
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO
and PRENTICE EARL SANDERS
9
10
11
Dated: June 18, 2013
KEKER & VAN NEST LLP
12
By:
13
15
S
22
pero
ph C. S
dge Jose
Ju
ER
A
H
21
RT
20
Dated: 6/19/13
NO
19
D
RDERE
FO
18
OO
IT IS S
LI
UNIT
ED
17
RT
U
O
16
Attorneys for Plaintiff
CARAMAD CONLEY
S DISTRICT **Pursuant to GO 45, the electronic signatory has
TE
C
TA
obtained approval from this signatory.
R NIA
14
/s/** ___________
ERIC H. MACMICHAEL
N
F
D IS T IC T O
R
C
23
24
25
26
27
28
STIPULATIONS REGARDING EVIDENCE
CV12-00454 JCS
3
n:\lit\li2012\070571\00848291.doc
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?