Unverferth et al v. Liberty Union High School District et al

Filing 79

STIPULATION AND ORDER re 77 JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER STATUS CONFERENCE. Status Report due by 1/19/2017. Status Conference set for 1/26/2017 10:30 AM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 12/1/16. (bpf, COURT STAFF) (Filed on 12/1/2016)

1 Stephanie Y. Wu, SBN 268948
MCCORMICK, BARSTOW, SHEPPARD,
2 WAYTE & CARRUTH LLP
1125 I Street, Suite 1
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Modesto, California 95354
4 T: [phone] | F: [phone]
[e-mail]
5 [e-mail]
6 Attorneys for Defendants LIBERTY UNION
HIGH SCHOOL DISTRICT, et al.
7

Todd Boley, SBN 68119
Justin Young, SBN 258062
LAW OFFICES OF TODD BOLEY
2381 Mariner Square Drive, Suite 280
Alameda, California 94501
T: [phone]
F: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiffs SARAH
UNVERFERTH, et al.

8 Peter W. Alfert, SBN 83139
HINTON ALFERT, P.C.
9 200 Pringle Avenue, Suite #450
Walnut Creek, California 94596
10 T: [phone]
F: [phone]
11 [e-mail]
12 Attorneys for Plaintiffs SARAH
UNVERFERTH, et al.
13
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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16 SARAH UNVERFERTH and P.C., a minor,
by and through his guardian ad litem SARAH
17 UNVERFERTH,
Plaintiffs,

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MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
1125 I ST., SUITE 1
MODESTO, CA 95354

JOINT STIPULATION AND [PROPOSED]
ORDER TO CONTINUE FURTHER
STATUS CONFERENCE

v.

20 LIBERTY UNION HIGH SCHOOL
DISTRICT, ERIC VOLTA, JOHN SAYLOR,
21 PATRICK WALSH, JENNIFER KOETT,
ILENE FOSTER, and SANDRA
22 GUARDADO, and DOES 1-30,
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Case No. 3:15-cv-01721-EMC

Judge: Hon. Edward M. Chen

Defendants.
STIPULATION
Plaintiffs SARAH UNVERFERTH and P.C., a minor, by and through his guardian ad litem
Sarah Unverferth (collectively “Plaintiffs”) and Defendants LIBERTY UNION HIGH SCHOOL
DISTRICT, ERIC VOLTA, JOHN SAYLOR, PATRICK WALSH, JENNIFER KOETT, ILENE
FOSTER, and SANDRA GUARDADO (collectively “Defendants”), by and through their counsel,
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STIPULATION AND [PROPOSED] ORDER
3:15-cv-01721-EMC

1 hereby stipulate as follows:
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WHEREAS, the parties and their counsel participated in mediation, per the court’s order, on

3 September 13, 2016 and reached an agreement to settle the entire action;
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WHEREAS, on September 30, 2016, the parties entered into a stipulation and the court signed

5 an order continuing the status conference of October 6, 2016 until December 8, 2016 (Doc. No. 76);
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WHEREAS, the parties have been diligently working to prepare the necessary documents and

7 pleadings required to effectuate settlement and dismiss the entire action, including a release of claims
8 and petition for approval of minor’s compromise;
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WHEREAS, the Plaintiffs have yet to complete all of the necessary paperwork pertaining to

10 the structure of the settlement due to significant family issues in the last two months, including an
11 unexpected death in the Plaintiffs’ immediate family;
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WHEREAS, the parties, in light of Plaintiffs’ inability to complete the needed paperwork

13 because of said family issues, have discussed and agreed to a 30-day continuance of the Further Status
14 Conference, currently scheduled for December 8, 2016;
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IT IS HEREBY STIPULATED, by and among the parties to this action, that the December 8,

16 2016 Further Status Conference be continued by at least 30 days.
17 IT IS SO STIPULATED.
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MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
1125 I ST., SUITE 1
MODESTO, CA 95354

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STIPULATION AND [PROPOSED] ORDER
3:15-cv-01721-EMC

1 Dated: December 1, 2016
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McCORMICK, BARSTOW, SHEPPARD,
WAYTE & CARRUTH LLP
/S/ STEPHANIE Y. WU
Stephanie Y. Wu
Attorneys for Defendants LIBERTY UNION
HIGH SCHOOL DISTRICT, et al.

By:

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7 Dated: December 1, 2016
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LAW OFFICES OF TODD BOLEY
/S/ JUSTIN P. YOUNG
Justin P. Young
Attorneys for Plaintiffs SARAH
UNVERFERTH, et al.

By:

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MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
1125 I ST., SUITE 1
MODESTO, CA 95354

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STIPULATION AND [PROPOSED] ORDER
3:15-cv-01721-EMC

1
[PROPOSED]
ORDER

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Pursuant to the foregoing Stipulation of the Parties, it is hereby ordered that:
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The Further Status Conference currently set for December 8, 2016 will be continued to

January 26, 2017

_________________ at 10:30 a.m.

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Dated: _____________, 2016

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DERED
SO OR ED
IT IS
_____________________________________
ODIFI
AS MEDWARD M. CHEN
HON.
UNITED STATES DISTRICT COURT JUDGE
n
M. Che
Edward
Judge

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Dec. 1

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IT IS SO ORDERED.

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UNIT
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49912-00188 4110636.1

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MCCORMICK, BARSTOW,
SHEPPARD, W AYTE &
CARRUTH LLP
1125 I ST., SUITE 1
MODESTO, CA 95354

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STIPULATION AND [PROPOSED] ORDER
3:15-cv-01721-EMC

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