Angell et al v. City of Oakland et al

Filing 37

ORDER GRANTING STIPULATION TO CONTINUE PLAINTIFFS' DEADLINE FOR FILING MOTION FOR CLASS CERTIFICATION, CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES 36 . Completion date of settlement conference with Judge Beeler is 7/31/2014. Last da te for plaintiffs to file class certification motion is 8/06/2014. Case Management Statement due 9/17/2014. Case Management Conference set for 9/24/2014 10:00 AM in Courtroom A, 15th Floor, San Francisco. Signed by Judge Nathanael Cousins on 4/28/14. (lmh, COURT STAFF) (Filed on 4/28/2014)

1 GREGORY J. ROCKWELL, ESQ. (SBN 67305)
[e-mail]
2 JILL P. SAZAMA, ESQ. (SBN 214215)
[e-mail]
3 BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation/File #27157
4 555 12th Street, Suite 1800
Oakland, CA 94607
5 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants
7 COUNTY OF ALAMEDA, GREGORY
AHERN, BRETT KETELES, CARLA
8 KENNEDY, DAVID BRADY, GREGORY
MORGADO and KERRY JACKSON
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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13 STEVEN ANGELL, MILES AVERY, MOLLY )
BATCHELDER, SRI LOUISE also known as )
14 Louise Coles, CICILY COOPER, SHAREEF )
ELFIKI, THEODORE HEXTON, LINDSAY )
15 WEBER, Individually and on behalf of others )
similarly situated,
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Plaintiffs,
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vs.
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CITY OF OAKLAND, COUNTY OF
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19 ALAMEDA, HOWARD JORDAN, JEFFREY )
ISRAEL, ERIC BRESHEARS, RON YELDER, )
20 DARREN ALLISON, STEVE TULL,
)
EDWARD TRACEY, ANTHONY RACHAL, )
21 SEAN WHENT, GREGORY J. AHERN,
)
BRETT KETELES, CARLA KENNEDY,
)
22 DAVID BRADY, GREGORY L. MORGADO, )
KERRY JACKSON, DOES 1-250,
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Defendants.
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Case No.: C13-0190 NC
STIPULATION TO CONTINUE
PLAINTIFFS’ DEADLINE FOR FILING
MOTION FOR CLASS CERTIFICATION
AND CASE MANAGEMENT
CONFERENCE AND ALL RELATED
DATES AND [PROPOSED] ORDER

Complaint Filed: January 14, 2013

The parties herein hereby stipulate and jointly apply to the Court for relief from existing

26 deadlines in the above-referenced matter as follows:
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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC

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The parties have participated in settlement conferences with Magistrate Judge Laurel

2 Beeler on January 13, February 24 and April 8, 2014. The parties and Judge Beeler feel that good
3 progress has been made toward reaching a resolution of the plaintiffs’ claims, and that a further
4 settlement conference would be beneficial. Judge Beeler and the parties have agreed to have a
5 fourth settlement conference on June 27, 2014 at 10:30 a.m. The parties and Judge Beeler also feel
6 that the interests of justice will be served, and the potential for a resolution of this matter will be
7 improved, if the current deadline for the plaintiffs to file a motion for class certification is
8 continued to permit the settlement process to continue.
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As a consequence, the parties jointly request that the Court continue the present deadlines

10 for completion of the settlement conference with Judge Beeler, for filing the motion for class
11 certification and the joint case management conference statement and the date of the case
12 management conference as follows:
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Completion of settlement conference with Judge Laurel Beeler: July 31, 2014

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Last date for plaintiffs to file motion for class certification: August 6, 2014

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Filing of joint case management conference statement: September 17, 2014

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Case management conference: September 24, 2014 at 10:00 a.m.

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DATED: April 28, 2014
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YOLANDA HUANG, ESQ.

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By:

/s/

YOLANDA HUANG, ESQ.
Attorneys for Plaintiffs

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Yolanda Huang

DATED: April 2, 2014
SIEGEL & YEE

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By:

Dan Siegel
DAN SIEGEL, ESQ.
Attorneys for Plaintiffs

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/s/

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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC

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DATED: April 28, 2014
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BARBARA J. PARKER, City Attorney
JAMES F. HODGKINS, Supervising Trial
Attorney

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By: __

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8 DATED: April 28, 2014
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/s/ James F. Hodgkins
JAMES F. HODGKINS, ESQ.
Attorneys for Defendants
CITY OF OAKLAND, et al

BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation

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By:

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/s/ Gregory J. Rockwell
GREGORY J. ROCKWELL, ESQ.
Attorneys for Defendants
COUNTY OF ALAMEDA, et al.

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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC

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ORDER
GOOD CAUSE appearing therefor, and the parties having so stipulated, the Court hereby

3 GRANTS the parties’ joint application for continuance of all existing deadlines and hearing and
4 filing dates as follows:
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Completion of settlement conference with Judge Laurel Beeler: July 31, 2014

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Last date for plaintiffs to file motion for class certification: August 6, 2014

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Filing of joint case management conference statement: September 17, 2014

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Case management conference: September 24, 2014 at 10:00 a.m.

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S

UNIT
ED

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GRAN

NO

12 Dated: April 28, 2014

thanael M
Judge Na

TED

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S DISTRICT
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IT IS SO ORDERED

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ER

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. Cousins

FO

NATHANAEL M. COUSINS
United States Magistrate Judge

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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC

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PROOF OF SERVICE BY ELECTRONIC SERVICE

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I, the undersigned, declare as follows:

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I am employed in the County of Alameda, State of California. I am over the age of 18

5 years and not a party to the within action. My business address is 555 12th Street, Suite 1800,
6 P. O. Box 12925, Oakland, California 94604-2925.
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On the date indicated below, at the above-referenced business location, I served the

8 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR
9 CLASS CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL
10 RELATED DATES AND [PROPOSED] ORDER on the below-named party and caused said
11 document to be transmitted using ECF as specified by General Order No. 45 to the following
12 party:
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Yolanda Huang, Esq.
P.O. Box 5475
Berkeley, CA 94705
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiffs STEVEN ANGELL,
MILES AVERY, MOLLY BATCHELDER,
SRI LOUISE also known as Louise Coles,
CICILY COOPER, SHAREEF ELFIKI,
THEODORE HEXTON, LINDSAY
WEBER, Individually and on behalf of
others similarly situated

Dan Siegel, Esq.
Anne Weills, Esq.
SIEGEL & YEE
499 14th Street, Suite 300
Oakland, CA 94612
Tel: [phone]
Fax: [phone]

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Barbara J. Parker, Esq.
Randolph W. Hall, Esq.
Oakland City Attorney's Office
One Frank H. Ogawa Plaza, 6th Fl.
Oakland, CA 94612
Tel: [phone]
Fax: [phone]
E-mail:
[e-mail]

Attorneys for Defendants CITY OF
OAKLAND, et al.

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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC

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Gregory A. Wedner, Esq.
William E. Simmons, Esq.
Lozano Smith
2001 North Main St., Ste. 650
Walnut Creek, CA 94596
Tel: [phone]
Fax: [phone]
E-mail:
[e-mail]

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I declare under penalty of perjury under the laws of the United States of America that the

7 foregoing is true and correct.
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Executed at Oakland, California, on April 28, 2014.
/s/ Candace Hankins
Candace Hankins

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27157\652673

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28 STIPULATION TO CONTINUE PLAINTIFFS’ DEADLINE FOR FILING MOTION FOR CLASS
CERTIFICATION AND CASE MANAGEMENT CONFERENCE AND ALL RELATED DATES AND
[PROPOSED] ORDER
Steven Angell, et al. vs. City of Oakland, et al.; USDC-Nor Dist. Case No. C13-0190 NC