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

Filing 55

ORDER GRANTING 54 STIPULATION CONTINUING CASE MANAGEMENT CONFERENCE: Case Management Statement due by 4/12/2013. Case Management Conference set for 4/19/2013 01:30 PM in Courtroom 11, 19th Floor, San Francisco.. Signed by Judge JEFFREY S. WHITE on 1/22/13. (jjoS, COURT STAFF) (Filed on 1/22/2013)

Case3:12-cv-00944-JSW Document54 Filed01/18/13 Page1 of 4

1 HANSON BRIDGETT LLP
RAYMOND F. LYNCH – 119065
2 [e-mail]
SARAH D. MOTT – 148597
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[e-mail]
4 JANE FEDDES – 282117
[e-mail]
5 425 Market Street, 26th Floor
San Francisco, CA 94105
6 Telephone:
[phone]
Facsimile:
[phone]
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COUNTY COUNSEL,
CONTRA COSTA COUNTY
SHARON L. ANDERSON - 94814
[e-mail] -nty.us
MARY ANN McNETT MASON - 115089
[e-mail]
651 Pine St., 9th Floor
Martinez, CA 94553
Telephone: [phone]
Facsimile: [phone]

14 Attorneys for Defendant
CONTRA COSTA COUNTY
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UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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19 RETIREE SUPPORT GROUP OF
CONTRA COSTA COUNTY,
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Plaintiff,

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v.

No. C12-00944 (JSW)
JOINT STIPULATION REQUESTING
CONTINUANCE OF CASE
MANAGEMENT CONFERENCE,
WITH [PROPOSED] ORDER
(N.D. Local Rule 6-1(a))

CONTRA COSTA COUNTY,

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Defendant.

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4932268.1

Defendant Contra Costa County (“County” or “Defendant”) and Plaintiff Retiree Support
Group of Contra Costa County (“Plaintiff”) (together, "the Parties") are calendared to appear for
-1JOINT STIPULATION TO EXTEND CMC AND [PROPOSED] ORDER
C 12-00944 (JSW)

Case3:12-cv-00944-JSW Document54 Filed01/18/13 Page2 of 4

1 the Initial Case Management Conference ("CMC") on February 1, 2013;
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WHEREAS, pursuant to the Court's Order of August 6, 2012 (Dkt. 37), the following

3 deadlines apply to the filing of the Second Amended Complaint, responsive pleadings and any
4 subsequent briefing schedule, including:
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a. Plaintiff will file its amended complaint within sixty (60) days after completion

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of the County's production or November 30, 2012;

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c. Because of the holidays and possible furloughs, the County will file its

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responsive pleading by January 9, 2013;

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d. If the County files a motion to dismiss, Plaintiff’s opposition brief will be filed

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twenty-five (25) days after the County files the motion; and

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e. The County’s reply brief will be filed eleven (11) days after the filing of Plaintiff's

12 opposition brief;
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WHEREAS, Plaintiff filed its Second Amended Complaint on November 30, 2012 (Dkt.

14 43);
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WHEREAS, Defendant filed its Motion to Dismiss the Second Amended Complaint (the

16 “Motion to Dismiss”) on January 9, 2012 (Dkt. 44-46);
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WHEREAS, briefing on the Motion to Dismiss will not be complete until February 15,

18 2013 (Dkt. 37);
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WHEREAS, the first available hearing date provided by the Court for hearing on the

20 Motion to Dismiss is March 29, 2013; and
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WHEREAS, for reasons of judicial economy based on the deadlines set forth herein, there

22 is good cause for the Court to continue the Case Management Conference scheduled for February
23 1, 2013, until after the Motion to Dismiss the Second Amended Complaint is decided;
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NOW THEREFORE, the Parties, by and through their respective counsel of record, hereby

25 stipulate and agree as follows, and respectfully ask the Court to enter the terms of this stipulation
26 as its Order, subject to amendment for good cause:
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4932268.1

For reasons of judicial economy, the Parties agree the Case Management Conference

28 scheduled for February 1, 2013, should be continued to a date to be set by the Court after the
-2JOINT STIPULATION TO EXTEND CMC AND [PROPOSED] ORDER
C 12-00944 (JSW)

Case3:12-cv-00944-JSW Document54 Filed01/18/13 Page3 of 4

1 Motion to Dismiss is decided.
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IT IS SO STIPULATED AND REQUESTED BY the Parties.

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HANSON BRIDGETT LLP

4 DATED: January 17, 2013
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By: /s/
RAYMOND F. LYNCH
Attorneys for Defendant
CONTRA COSTA COUNTY

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9 DATED: January 17, 2013

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

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By: /s/
JEFFREY LEWIS
Attorneys for Plaintiff
RETIREE SUPPORT GROUP OF CONTRA
COSTA COUNTY

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ORDER

16 PURSUANT TO THE FOREGOING STIPULATION AND REQUEST, and for good cause
April 19, 2013
17 shown, the Court resets the Case Management Conference to _____________________.
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IT IS SO ORDERED.

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20 Dated:

January 22 , 2013
HON. JEFFREY S. WHITE
United States Judge

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4932268.1

-3JOINT STIPULATION TO EXTEND CMC AND [PROPOSED] ORDER
C 12-00944 (JSW)