Manzanillo v. Lewis et al

Filing 162

STIPULATION AND ORDER re 161 STIPULATION WITH PROPOSED ORDER TO STAY THIS ACTION FOR A PERIOD OF FOUR WEEKS AND TO CONTINUE THE CASE MANAGEMENT CONFERENCE SCHEDULED FOR JULY 8, 2015 filed by Raymond J. Manzanillo. Case Management Statement due by 8/7/2015. Initial Case Management Conference set for 8/19/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on June 26, 2015. (wsn, COURT STAFF) (Filed on 6/26/2015)

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SEYFARTH SHAW LLP
Francis J. Ortman III (SBN 213202); [e-mail]
Aryeh M. Hersher (SBN 260321); [e-mail]
Jason M. Allen (SBN 284432); [e-mail]
Michael A. Wahlander (SBN 260781); [e-mail]
560 Mission Street, 31st Floor, San Francisco, California 94105
Telephone: [phone] / Facsimile: [phone]
Attorneys for Plaintiff
RAYMOND J. MANZANILLO

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MCNAMARA LAW FIRM
Peter Jon Hirsig; [e-mail]
William Lee McCaslin; [e-mail]
639 Kentucky Street, First Floor, Fairfield, CA 94533
Telephone: [phone] / Facsimile: [phone]

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Attorneys for Defendant
N. BROWN
Michael James Quinn; [e-mail]
California State Attorney General’s Office
Correctional Law Section
455 Golden Gate Avenue, Suite 11000,
San Francisco, CA 94102-7004
Telephone: [phone] / Facsimile: [phone]

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Attorneys for Defendants
GREGORY D. LEWIS; J. HALLOCK; K. MCGUYER;
MATTHEW CATE AND T.A. WOOD

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RAYMOND J. MANZANILLO,

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Plaintiff,
v.

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GREGORY D. LEWIS, et al.,

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Case No. 3:12-cv-05983-JST
STIPULATION AND [PROPOSED]
ORDER TO STAY THIS ACTION FOR A
PERIOD OF FOUR WEEKS AND TO
CONTINUE THE CASE MANAGEMENT
CONFERENCE SCHEDULED FOR
JULY 8, 2015

Defendants.

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STIPULATION AND [PROPOSED] ORDER / CASE NO. 3:12-CV-05983-JST

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Pursuant to Civil Local Rule 6-2, Plaintiff Raymond J. Manzanillo and Defendants N. Brown,

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Gregory D. Lewis, J. Hallock, K. McGuyer, Matthew Cate, and T.A. Wood (collectively “the Parties”)

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by and through their respective counsel hereby stipulate and request that the Court (1) stay this action

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for a period of four weeks from the date of the Court’s Order granting this request; (2) continue the case

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management conference currently scheduled for July 8, 2015, to a date convenient for the Court that

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follows the end of the stay; and (3) continue the current July 1, 2015, deadline for the Parties to file case

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management statements.

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Plaintiff’s counsel is currently working with personnel at Corcoran State Prison to gain access to
Mr. Manzanillo. That process has taken longer than expected, and Plaintiff’s counsel has not yet been

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able to meet or speak with Mr. Manzanillo; nor has counsel yet been able to secure copies of documents

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produced to Mr. Manzanillo in discovery thus far. The proposed stay will require the Court to

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reschedule the July 8 case management conference and extend the deadline for the Parties to file a case

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management statement, but it should not otherwise have a significant effect on the schedule for this case.

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Moreover, the requested stay will preserve both the Parties’ and the Court’s resources, as it will allow

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Plaintiff’s counsel the opportunity to confer with Mr. Manzanillo and review the materials already

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produced by Defendants before participating in a case management conference or any additional

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litigation practice.

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IT IS SO STIPULATED.

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DATED: June 24, 2015

Respectfully submitted,

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SEYFARTH SHAW LLP

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By: /s/ Michael A. Wahlander
Francis J. Ortman III
Aryeh M. Hersher
Jason M. Allen
Michael A. Wahlander

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Attorneys for Plaintiff
RAYMOND J. MANZANILLO

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STIPULATION AND [PROPOSED] ORDER / CASE NO. 3:12-CV-05983-JST

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DATED: June 24, 2015

Respectfully submitted,

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MCNAMARA LAW FIRM

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By: /s/ William Lee McCaslin
Peter Jon Hirsig
William Lee McCaslin

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Attorneys for Defendant
N. BROWN

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DATED: June 24, 2015

Respectfully submitted,

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CALIFORNIA STATE ATTORNEY
GENERAL’S OFFICE

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By: /s/ Michael James Quinn
Michael James Quinn

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Attorneys for Defendants
GREGORY D. LEWIS; J. HALLOCK;
K. MCGUYER; MATTHEW CATE AND
T.A. WOOD

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ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3)
I, Michael A. Wahlander, attest that concurrence in the filing of this stipulation has been

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obtained from the signatories, William Lee McCaslin and Michael James Quinn, counsel for

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Defendants.

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Executed this 24th day of June, 2015, in San Francisco, CA.

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____/s/ Michael A. Wahlander ___________________
Michael A. Wahlander

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STIPULATION AND [PROPOSED] ORDER / CASE NO. 3:12-CV-05983-JST

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[PROPOSED] ORDER

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Based on the Parties’ stipulation and good cause appearing, the Court orders as follows:

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1.

All further proceedings are STAYED for four weeks from the date of this order.

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2.

The Case Management Conference currently scheduled for July 8, 2015, is hereby

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rescheduled to August 19, and the deadline for the Parties’ to file Case Management Statements,

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currently July 1, 2015, will be rescheduled to August 7, 2015.

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DATED: June 26, 2015
HONORABLE JON S. TIGAR
United States District Judge

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STIPULATION AND [PROPOSED] ORDER / CASE NO. 3:12-CV-05983-JST