Myrah Martinez et al v. County of Sonoma et al

Filing 28

STIPULATION AND ORDER re 27 STIPULATION WITH PROPOSED ORDER to Continue Case Management Conference and Associated Deadlines filed by Jenifer Stum, R.M., S.S., Kitara McCray, Madison Marlene Marvel, Myrah Martinez. Case Management Statement due by 8/24/2015. Initial Case Management Conference set for 9/2/2015 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on July 8, 2015. (wsnS, COURT STAFF) (Filed on 7/8/2015)

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Mark E. Merin (State Bar No. 043849)
Paul H. Masuhara (State Bar No. 289805)
LAW OFFICE OF MARK E. MERIN
1010 F Street, Suite 300
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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Bonnie A. Freeman, Esq. (SB 180502)
SENNEFF FREEMAN & BLUESTONE, LLP
50 Old Courthouse Square, Suite 401
P.O. Box 3729
Santa Rosa, CA 95402-3729
Telephone:
707-526-4250
Facsimile:
707-526-0347
[e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No. 3:15-cv-01953-JST

MYRAH MARTINEZ, et al.,

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Plaintiffs,

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vs.

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STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
ASSOCIATED DEADLINES;
[PROPOSED] ORDER

COUNTY OF SONOMA, et al.,

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Defendants.

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WHEREAS, the Court’s currently-scheduled Case Management Conference in the above-

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captioned is set for August 5, 2015. ECF No. 9. Dates associated with the Case Management Conference

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include the parties’ obligation to meet and confer by July 15, 2015, pursuant to Federal Rule of Civil

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Procedure 26(f)(1); the parties’ obligation to exchange initial disclosures within 14 days of their meet and

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confer, pursuant to Federal Rule of Civil Procedure 26(a)(C); and the parties’ obligation to file a Joint

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Case Management Statement by July 27, 2015.

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WHEREAS, the pendency of Defendants’ motion to dismiss (ECF No. 19) and Plaintiffs’

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counsels’ unavailability during the month of July creates good cause to delay the above-referenced dates

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST

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and deadlines, the parties hereby STIPULATE to the following:

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1.

the Court’s rescheduling of the Case Management Conference to September 2, 2015;

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2.

the parties’ obligation to meet and confer by August 12, 2015, pursuant to Federal Rule of

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Civil Procedure 26(f)(1);
3.

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the parties’ obligation to exchange initial disclosures within 14 days of their meet and
confer, pursuant to Federal Rule of Civil Procedure 26(a)(C); and

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the parties’ obligation to file a Joint Case Management Statement by August 24, 2015.

Dated: July 6, 2015

Respectfully Submitted,

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LAW OFFICE OF MARK E. MERIN

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/s/ Mark E. Merin
By: __________________________________
Mark E. Merin

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Attorneys for Plaintiffs
MYRAH MARTINEZ, KITARA MCCRAY,
MADISON MARLENE MARVEL, STAR SMITH,
and R.M.

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Dated: July 6, 2015

Respectfully Submitted,
SENNEFF FREEMAN & BLUESTONE, LLP

/s/ Bonnie A. Freeman
(as authorized on July 6, 2015)
By: __________________________________
Bonnie A. Freeman
Attorneys for Defendants County of Sonoma (also sued as
Sonoma County Human Services Department and Sonoma
County Family, Youth and Children’s Services), Jerry
Dunn, Nick Honey and Stacie Kabour

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST

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[PROPOSED] ORDER

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Pursuant to the parties’ stipulation, the Court hereby ORDERS the following:

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1.

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2015;
2.

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of Civil Procedure 26(f)(1);
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Dated: July 8, 2015

ISTRIC
ES D
TC
T
TA

ERED
O ORD
_________________________________________
IT IS S

R NIA

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IT IS SO ORDERED.

JON S. TIGAR, DISTRICT JUDGE
UNITED STATES DISTRICT COURT

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J u d ge J o

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Ti ga r

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the parties are obligated to file a Joint Case Management Statement by August 24, 2015.

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4.

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confer, pursuant to Federal Rule of Civil Procedure 26(a)(C); and

UNIT
ED

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the parties are obligated to exchange initial disclosures within 14 days of their meet and

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the parties are obligated to meet and confer by August 12, 2015, pursuant to Federal Rule

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the Case Management Conference is rescheduled from August 5, 2015 to September 2,

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE AND ASSOCIATED DEADLINES; [PROPOSED] ORDER
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST