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

Filing 182

STIPULATION AND ORDER re 181 STIPULATION WITH PROPOSED ORDER Stipulation That No Response To Third Amended Complaint For Settlement Purposes Is Necessary And Alternatively And Additionally An Extension Of Time To Respond To Third Amended Complaint filed by Contra Costa County. Signed by Judge Jon S. Tigar on July 11, 2016. (wsn, COURT STAFF) (Filed on 7/11/2016)

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
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HANSON BRIDGETT LLP
7 RAYMOND F. LYNCH, SBN 119065
[e-mail]
8 LAWRENCE M. CIRELLI, SBN 114710
[e-mail]
9 STEPHEN B. PECK, SBN 72214
[e-mail]
10 MATTHEW J. PECK, SBN 287934
[e-mail]
11 425 Market Street, 26th Floor
San Francisco, California 94105
12 Telephone:
[phone]
Facsimile:
[phone]
13
COUNTY COUNSEL, CONTRA COSTA COUNTY
14 SHARON L. ANDERSON, SBN 94814
[e-mail]
15 MARY ANN McNETT MASON, SBN 115089
[e-mail]
16 651 Pine St., 9th Floor
Martinez, California 94553
17 Telephone:
[phone]
Facsimile:
[phone]
18
Attorneys for Defendant
19 CONTRA COSTA COUNTY
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12501593.1

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

22 RETIREE SUPPORT GROUP OF CONTRA
CASE NO. C 12-00944 JST
COSTA COUNTY, MICHAEL SLOAN;
23 ALYN D. GOLDSMITH; DEBORAH ELITE; STIPULATION THAT NO RESPONSE TO
THIRD AMENDED COMPLAINT FOR
BILLIE JO WILSON ELKIN; SUSANNE
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SETTLEMENT PURPOSES IS
BEADLE; and ALICE GROTHMANN;
NECESSARY AND ALTERNATIVELY
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AND ADDITIONALLY AN EXTENSION
Plaintiffs,
OF TIME TO RESPOND TO THIRD
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AMENDED COMPLAINT
v.
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Judge: Hon. Hon. Jon S. Tigar
CONTRA COSTA COUNTY,
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Defendant.
C 12-00944 JST
Stipulation That No Response To 3rd Amended Complaint Is Necessary
And An Open Extension Of Time To Respond

1

1.

Plaintiffs Retiree Support Group of Contra Costa County (“Plaintiff RSG”),

2 Plaintiffs MICHAEL SLOAN; ALYN D. GOLDSMITH; DEBORAH ELITE; BILLIE JO
3 WILSON ELKIN; SUSANNE BEADLE; and ALICE GROTHMANN (collectively "Plaintiff
4 Class Representatives") and Defendant Contra Costa County ("Defendant County") have entered
5 into a comprehensive written settlement agreement (“Agreement”) which the Court preliminarily
6 approved on June 14, 2016 (ECF 169). The terms of the Agreement required Plaintiff RSG to file
7 a Third Amended Complaint alleging a class action and seeking damages. Plaintiff RSG and
8 Plaintiff Class Representatives filed their Third Amended Complaint on June 16, 2016.
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2.

The Parties agree that no pleading responding to the Third Amended Complaint is

10 necessary at this time since under the terms of the Agreement provide that the Third Amended
11 Complaint was filed solely for settlement purposes, and will be withdrawn and have no force and
12 effect, if the settlement is not fully implemented.
13

3.

Alternatively and additionally, the Parties agree and stipulate that Defendant

14 County’s time for response is extended to and including twenty (20) days after the Fairness
15 Hearing to finally approve the Agreement on October 25, 2016.
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12501593.1

-2C 12-00944 JST
Stipulation That No Response To 3rd Amended Complaint Is Necessary
And An Open Extension Of Time To Respond

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IT IS SO STIPULATED.

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3 DATED: July 6, 2016

KELLER ROHRBACK, L.L.P.

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By:
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/s/ Jeffrey Lewis
JEFFREY LEWIS
Attorneys for Plaintiffs
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY, MICHAEL SLOAN,
DEBORAH ELITE, SUSANNE BEADLE,
BILLIE JOE WILSON ELKIN, ALYN
GOLDSMITH, AND ALICE GROTHMANN

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10 DATED: July 5, 2016

HANSON BRIDGETT LLP

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By:

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/s/ Raymond F. Lynch
RAYMOND F. LYNCH
LAWRENCE M. CIRELLI
STEPHEN B. PECK
MATTHEW J. PECK
Attorneys for Defendant
CONTRA COSTA COUNTY

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IT IS SO ORDERED.
July 11
Dated: _________________, 2016
HONORABLE JON S. TIGAR
United States District Court Judge

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12501593.1

-3C 12-00944 JST
Stipulation That No Response To 3rd Amended Complaint Is Necessary
And An Open Extension Of Time To Respond

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SIGNATURES UNDER GENERAL ORDER NO. 45
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.
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By:

/s/ Raymond L Lynch
Raymond L. Lynch

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12501593.1

-4C 12-00944 JST
Stipulation That No Response To 3rd Amended Complaint Is Necessary
And An Open Extension Of Time To Respond