Retiree Support Group of Contra Costa County v. Contra Costa County

Filing 114

STIPULATION AND ORDER re 113 STIPULATION WITH PROPOSED ORDER Stipulation Extending Case Deadlines and [Proposed] Order filed by Contra Costa County. Signed by Judge Jon S. Tigar on March 5, 2015. (wsn, COURT STAFF) (Filed on 3/5/2015)

1 LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
JEFFREY LEWIS, SBN 066587
2 [e-mail]
ANDREW LAH, SBN 234580
3 [e-mail]
DARIN RANAHAN, SBN 273532
4 [e-mail]
MICHAEL CAESAR, SBN 280548
5 [e-mail]
6 LINDA LAM, SBN 301461
[e-mail]
th
7 476 9 Street
Oakland, CA 94607
[phone]
8 Telephone:
Facsimile:
[phone]
9
HANSON BRIDGETT LLP
10 RAYMOND F. LYNCH, SBN 119065
[e-mail]
11 LAWRENCE M. CIRELLI, SBN 114710
[e-mail]
12 STEPHEN B. PECK, SBN 72214
[e-mail]
13 MATTHEW J. PECK, SBN 287934
[e-mail]
14 425 Market Street, 26th Floor
San Francisco, CA 94105
[phone]
15 Telephone:
Facsimile:
[phone]
16
Attorneys for Defendant
17 CONTRA COSTA COUNTY
18

UNITED STATES DISTRICT COURT

19

NORTHERN DISTRICT OF CALIFORNIA

20
21 RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY,
22
Plaintiff,
23
v.
24
CONTRA COSTA COUNTY,
25
Defendant.
26
27

CASE NO. C 12-00944 JST
STIPULATION EXTENDING CASE
DEADLINES AND [PROPOSED] ORDER
Judge:

Hon. Jon S. Tigar

This is a complex case involving claims brought by Plaintiff Retiree Support Group of

28 Contra Costa County ("RSG") on behalf of retirees of Defendant Contra Costa County (the
10896284.6

C 12-00944 JST
STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

1 "County") (collectively, the "Parties") claiming a vested right in certain healthcare subsidies as is
2 more fully stated in Plaintiff's First Amended Complaint.
3

The Parties have engaged in substantial discovery and there still remains a significant

4 amount of discovery to be completed before this case is ready for trial;
5

RSG and the County have agreed to engage in mediation and to devote their best efforts to

6 that process, which will be complex and time consuming given the nature of this case;
7

The Parties wish to continue the trial date for 6.5 months (201 days), and to continue case

8 deadlines accordingly, to allow the Parties sufficient time to explore settlement through mediation;
9

The Court's Scheduling Orders provide the present case deadlines (Dkts. 91, 97 and 112);

10

The Parties, by and through their respective counsel of record, hereby stipulate and agree

11 that there is good cause to continue all case deadlines as follows pursuant to Federal Rule of Civil
12 Procedure 16 and Civil Local Rule 16-10 and request the Court approve and so order:
13
14

Event

Deadline

Case Management Conference

9/3/15

Expert disclosures

9/14/15

Fact discovery cut-off

10/12/15

Expert rebuttal

10/14/15

Expert discovery cut-off

10/30/15

Deadline to file dispositive motions

11/6/15

Pretrial conference statement due

1/5/16

Pretrial conference

22

1/12/16 at 2:00 p.m. or such other date
available on the Court’s schedule

23

1/22/16 at 2:00 p.m.

15
16
17
18
19
20
21

24

Bench trial

2/15/16 at 8:30 a.m. or such other date
available on the Court's trial schedule

25
26 / / /
27 / / /
28
10896284.6

-2STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST

1 ///
2
IT IS SO STIPULATED.
3
DATED: March 3, 2015

LEWIS, FEINBERG, LEE, RENAKER &
JACKSON, P.C.

4
5
6

By:

7
8

/s/
ANDREW LAH
Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY

9
10

DATED: March 3, 2015

HANSON BRIDGETT LLP

11
By:

12
13

/s/
RAYMOND F. LYNCH
Attorneys for Defendant
CONTRA COSTA COUNTY

14
15
16
17

IT IS SO ORDERED.
Dated: March 5, 2015
HONORABLE JON S. TIGAR
United States District Court Judge

18
19
20
21
22
23
24
25
26
27
28
10896284.6

-3STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST

1

SIGNATURES UNDER GENERAL ORDER NO. 45

2 Pursuant to General Order No. 45 of the United States District Court, Northern District of
3 California, I, Raymond F. Lynch—the ECF User whose User ID and Password are used in the
4 filing of this document—hereby attest that the concurrence to the filing of this document has been
5 obtained from each of the other signatories to this document.
6
/s/
Raymond F. Lynch

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
10896284.6

-4STIPULATION EXTENDING CASE DEADLINES AND [PROPOSED] ORDER

C 12-00944 JST