Hall et al v. Housing Authority of the County of Marin

Filing 83

STIPULATION AND ORDER RE ADMINISTRATIVE MOTION TO SEAL DOCKET NOS. 62, 63, AND 65. Signed by Judge Richard Seeborg on 6/9/14. (cl, COURT STAFF) (Filed on 6/9/2014)

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Frank Sommers (State Bar No. 109012)
Andrew Schwartz (State Bar No. 100210)
SOMMERS & SCHWARTZ LLP
One Embarcadero Center, Suite 800
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Maura Prendiville (State Bar No. 257514)
LEGAL AID OF MARIN
30 N. San Pedro Road, Suite 220
San Rafael, CA 94903
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Jacquelyn Hall,
Ariana Martinez, Karla Fernandez,
Chavon White, and Esther Williams

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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JACQUELYN HALL, ARIANA MARTINEZ,
KARLA FERNANDEZ, CHAVON WHITE,
and ESTHER WILLIAMS for themselves and
all others similarly situated,

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STIPULATION AND [PROPOSED] ORDER
RE ADMINISTRATIVE MOTION TO SEAL
DOCKET NOS. 62, 63, AND 65

Plaintiffs,

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Case No.: C 12-04922 RS

vs.
HOUSING AUTHORITY OF THE COUNTY
OF MARIN, and DOES 1 through 100,
INCLUSIVE,
Defendants.

Judge: Honorable Richard Seeborg
Date Action Filed: September 20, 2012
Trial Date: Not Yet Rescheduled

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STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE MOTION TO SEAL
DOCKET NOS. 62, 63, AND 65
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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WHEREAS, Plaintiffs filed their Memorandum of Points and Authorities in Support of the

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Preliminary Approval of the Settlement (Docket No. 62), their Memorandum of Points and

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Authorities in Support of the Application for an Award of Attorneys’ Fees and Costs (Docket No.

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63), and Declaration of Frank Sommers in Support of Application for Attorneys’ Fees and Costs

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(Docket No. 65) on May 1, 2014;
WHEREAS, Defendant’s Counsel transmitted his letter of May 19, 2014, objecting to

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statements in these motion papers, contending that they violated the mediation privilege and the

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Settlement Agreement and unduly disparaged Defendant’s Counsel, and requesting the replacement

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of these papers with statements Defendant’s Counsel deemed “offending” to be “removed;”

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WHEREAS, Plaintiffs’ Counsel rejects the contentions in Defendant’s Counsel’s May 19th

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letter and believes that its initial papers did not violate the Settlement Agreement or the mediation

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privilege and did not unduly disparage Defendant’s Counsel. Plaintiffs’ Counsel made changes to

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many of the sections of the papers that Defendant’s Counsel had found “offending” in what it has

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now served as its Amended Notice of Motion and Motion For Award of Attorneys’ Fees and

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Amended Declaration of Frank F. Sommers, and has agreed to seek an order through an

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Administrative Motion to Place Docket Nos. 62, 63, and 65 under seal pursuant to Local Rules

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Section 7-11; and,
WHEREAS, as had been previously agreed between the Court and the parties on the recent

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hearing on Plaintiffs’ Motion for Preliminary Approval of the Settlement, Plaintiffs’ Amended

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Notice of Motion and Motion for an Award of Attorneys’ Fees and Costs does not identify

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insurance carriers of the Housing Authority of the County of Marin.

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STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE MOTION TO SEAL
DOCKET NOS. 62, 63, AND 65
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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NOW THEREFORE, Plaintiffs and Defendant stipulate to an order of this Court sealing

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Docket Nos. 62, 63, and 65, in this matter forthwith. The parties therefore request that the Court

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approve this Stipulation and authorize the sealing of Docket Nos. 62, 63, and 65 herein.

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IT IS SO STIPULATED.

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DATED: May 29, 2014

SOMMERS & SCHWARTZ LLP

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/s/ Andrew Schwartz
By: Andrew Schwartz, Attorneys for Plaintiffs
Jacquelyn Hall, Ariana Martinez, Karla
Fernandez, Chavon White, and Esther Williams

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DATED: May 30, 2014

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CHOLAKIAN & ASSOCIATES

/s/ Colin Jewell
By: Colin Jewell, Attorneys for
Defendant Housing Authority of the County of
Marin

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IT IS SO ORDERED.

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DATED: 6/9/14
Honorable Richard Seeborg
U.S. DISTRICT COURT

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STIPULATION AND [PROPOSED] ORDER RE ADMINISTRATIVE MOTION TO SEAL
DOCKET NOS. 62, 63, AND 65
U.S. DISTRICT COURT CASE NO. C 12-04922 RS

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