March v. Twin Cities Police Authority et al

Filing 50

ORDER, Motions terminated: 49 STIPULATION WITH PROPOSED ORDER Continuing Case Management Conference filed by Anita Rimes, Sky Woodruff, City of Larkspur, Dan Schwarz, Leonard Rifkind, Cynthia Huisman, Robert Sinnott. Status Conference set for 7/18/14 is continued to 8/29/2014 02:30 PM in Courtroom 10, 19th Floor, San Francisco before Hon. Susan Illston.. Signed by Judge Susan Illston on 7/8/14. (tfS, COURT STAFF) (Filed on 7/8/2014)

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Clifford Campbell, SBN: 60734
Kimberly M. Drake, SBN: 209090
JARVIS, FAY, DOPORTO & GIBSON, LLP
492 Ninth Street, Suite 310
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Defendants CITY OF LARKSPUR,
LEONARD RIFKIND, DAN SCHWARZ, ROBERT
SINNOTT, CYNTHIA HUISMAN, SKY
WOODRUFF, AND ANITA RIMES

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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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GLEN MARCH,

CASE NO. CV 14-00512 SI

Plaintiff,

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JOINT STIPULATION AND
[PROPOSED] ORDER CONTINUING
CASE MANAGEMENT CONFERENCE

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v.

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TWIN CITIES POLICE AUTHORITY, et al.,
Defendants.

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RECITALS

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1.

On July 11, 2014 the parties are required to file their Joint Case Management Conference

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Statement. On July 18, 2014 the parties are scheduled to attend the Case Management Conference,

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which is to be held at 2:30 p.m. in Courtroom 10.

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2.

Also on July 11, 2014 at 9:00 a.m. the Court is scheduled to hear motions by all

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defendants, by which they seek to dismiss the Plaintiff’s First Amended Complaint, or seek to strike

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those provisions from the Complaint which apply to them.

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3.

The parties have stipulated and agreed that it would be beneficial to all of them if the

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Case Management Conference and its associated Case Management Conference Statement were

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postponed 30 days from their currently scheduled dates. This will provide them with the opportunity to
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Joint Stipulation and [Proposed] Order Continuing Case Management Conference

Case No. CV 14-00512 SI

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learn the Court’s rulings on the various pending motions before they prepare for the Case Management

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Conference. The parties seek for the Case Management Conference to be rescheduled to the week of

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August 18, 2014.

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4.

Good cause exists for such a postponement. No defendant has yet answered. The

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pleadings are not yet settled. The current Case Management Conference was scheduled before two

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defendants, Sky Woodruff and Anita Rimes, ever entered their appearances in this action. After those

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new defendants did so the Court scheduled all pending motions, including those previously scheduled by

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the other defendants, to their current date of July 11. The pending motions are potentially dispositive.

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The parties do not yet know, therefore, how many defendants will remain in the case after the Court

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rules on the various pending motions. Nor do the parties yet know what issues they will face after the

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Court rules, what Initial Disclosures they will make, and what discovery will be required. Without such

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knowledge, the parties are not able to prepare a meaningful discovery schedule, or otherwise address the

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various topics required within their Joint Case Management Conference Statement.

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STIPULATION
1.

It is hereby stipulated that the Joint Case Management Conference, currently scheduled

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for July 18, 2014, at 2:30 p.m. in Courtroom 10, may be postponed, and rescheduled for the first

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available date on the Court’s calendar, during the week of August 18, 2014, at the hour of 2:30 p.m.

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2.

It is further stipulated that the parties’ deadline for submission of their Joint Case

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Management Conference statement, currently set for July 11, 2014, may be postponed until one week

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before the rescheduled Case Management Conference date.

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Dated: July 7, 2014

By:

/s/
Glen March
Plaintiff in propria persona

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Joint Stipulation and [Proposed] Order Continuing Case Management Conference

Case No. CV 14-00512 SI

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JARVIS, FAY, DOPORTO & GIBSON, LLP

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Dated: July 7, 2014

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By:

/s/
Clifford Campbell
Attorneys for Defendants CITY OF LARKSPUR,
LEONARD RIFKIND, DAN SCHWARZ, ROBERT
SINNOTT, CYNTHIA HUISMAN, SKY WOODRUFF
AND ANITA RIMES

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BERTRAND, FOX & ELLIOTT

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Dated: July 7, 2014

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By:

/s/
Richard Osman
Attorneys for Defendants CENTRAL MARIN POLICE
AUTHORITY, JAMES SHIRK, DAVID WOO, JENNA
MCVEIGH and HAMID KHALILI

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[PROPOSED] ORDER
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Pursuant to the stipulation of the parties, the Case Management Conference shall be, and is

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hereby continued to August ____, 2014 at 2:30 p.m. in Courtroom 10. The Joint Case Management

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Conference Statement shall be filed one week prior to the conference.

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7/8/14
_____________________________
DATED

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SUSAN ILLSTON
UNITED STATES DISTRICT COURT JUDGE

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Joint Stipulation and [Proposed] Order Continuing Case Management Conference

Case No. CV 14-00512 SI

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DECLARATION OF SERVICE

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I, the undersigned, declare as follows:

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I am a citizen of the United States and employed in the County of Alameda; I am over the age of

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eighteen years and not a party to the within entitled action; my business address is Jarvis, Fay, Doporto

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& Gibson, LLP, 492 Ninth Street, Suite 310, Oakland, California 94607.

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On July 7, 2014, I served the within:

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JOINT STIPULATION AND [PROPOSED] ORDER CONTINUING CASE
MANAGEMENT CONFERENCE

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on the parties in this action, by placing a true copy thereof in a sealed envelope(s), each envelope
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addressed as follows:
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Glen A. March
205 East Third Street, Suite 400
San Mateo, CA 94402

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In Pro Per

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(X)

(By First Class Mail) I caused each such envelope, with postage thereon fully
prepaid, to be placed in the United States mail to be mailed by First Class mail at
Oakland, California.

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(By Hand) I personally delivered each such envelope to the offices of each
addressee above.

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(By Facsimile) I caused each such document(s) to be sent via facsimile to the
addressee(s) above.

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(By Federal Express) I caused each such envelope to be sent by Federal Express to
the offices of each addressee above.

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I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
Executed on July 7, 2014, at Oakland, California.

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/s/
Jennifer Oberholzer

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Joint Stipulation and [Proposed] Order Continuing Case Management Conference

Case No. CV 14-00512 SI