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

Filing 135

STIPULATION AND ORDER re 134 STIPULATION WITH PROPOSED ORDER re 133 Stipulation and Order, STIPULATION CHANGING HEARING DATE AND [PROPOSED] ORDER filed by Contra Costa County. Signed by Judge Jon S. Tigar on February 3, 2016. (wsn, COURT STAFF) (Filed on 2/3/2016)

1 KELLER ROHRBACK, L.L.P.
JEFFREY LEWIS, SBN 066587
2 [e-mail]
300 Lakeshore Drive, Suite 1000
3 Oakland, CA 94612
Telephone:
[phone]
4 Facsimile:
[phone]
5 Attorneys for Plaintiff RETIREE SUPPORT GROUP
OF CONTRA COSTA COUNTY and the PUTATIVE CLASS
6
7 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
8 [e-mail]
LAWRENCE M. CIRELLI, SBN 114710
9 [e-mail]
STEPHEN B. PECK, SBN 72214
10 [e-mail]
MATTHEW JOSEPH PECK, SBN 287934
11 [e-mail]
425 Market Street, 26th Floor
12 San Francisco, CA 94105
Telephone:
[phone]
13 Facsimile:
[phone]
14 Attorneys for Defendant
CONTRA COSTA COUNTY
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

18 RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY,
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Plaintiff,
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v.
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CONTRA COSTA COUNTY,
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Defendant.
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CASE NO. C 12-00944 JST
STIPULATION CHANGING HEARING
DATE AND [PROPOSED] ORDER
Judge: Hon. Jon S. Tigar

1. The Court's current Scheduling Order (Dkt. 133) granted the parties' request (Dkt. 132)

25 to extend to March 17, 2016 the date for the parties to file a motion seeking orders Granting
26 Preliminary Approval of the Final Settlement Agreement, Authorizing the Filing of the Third
27 Amended Complaint, Preliminarily Certifying the Class for Settlement Purposes Only, and
28 Approving the Proposed Form of Notice and Plan for Providing Notice Submitted by the Parties.
11875658.1

C 12-00944 JST
STIPULATION CHANGING HEARING DATES AND [PROPOSED] ORDER

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2. The Court's Order (Dkt.133) changed the hearing date on the motion from April 7, 2016

2 to April 21, 2016. Due to the unavailability of both Plaintiff's and Defendant's lead counsel on
3 April 21, 2016 the Parties request the Court set the hearing on the motion on April 14, 2016.
4 Plaintiff's lead counsel, Jeffrey Lewis, will be out of the State of California from April 21 through
5 May 2, 2016 on a trip for which non-refundable airplane tickets and hotel reservations were made.
6 Defendant's lead counsel, Raymond F. Lynch. is lead counsel in an international arbitration
7 scheduled from April 18 through April 22, 2016 with witnesses from out of state and from other
8 countries.
9

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

10 that there is good cause to change the motion hearing date as follows pursuant to Federal Rule of
11 Civil Procedure 16 and Civil Local Rule 16-10 and request the Court approve and so order:
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Event

Deadline

Hearing date for motion seeking orders Granting April 14, 2016
Preliminary Approval of this Agreement,
Authorizing the Filing of the Third Amended
Complaint, Preliminarily Certifying the Class for
Settlement Purposes Only, and Approving the
Proposed Form of Notice and Plan for Providing
Notice Submitted by the Parties.

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IT IS SO STIPULATED.

19 DATED: February 1, 2016

KELLER ROHRBACK, L.L.P.

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By:

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24 DATED: February 1, 2016

/s/ Jeffrey Lewis
JEFFREY LEWIS
Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY
HANSON BRIDGETT LLP

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By:

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

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-2STIPULATION CHANGING HEARING DATE AND [PROPOSED] ORDER

C 12-00944 JST

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IT IS SO ORDERED.

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2 Dated: February __, 2016
HONORABLE JON S. TIGAR
United States District Court Judge

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C 12-00944 JST

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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 attests 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
Raymond F. Lynch

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-4STIPULATION CHANGING HEARING DATE AND [PROPOSED] ORDER

C 12-00944 JST