K.H. v. Secretary of the Department of Homeland Security

Filing 131

STIPULATION AND ORDER re 130 STIPULATION WITH PROPOSED ORDER Re Settlement filed by Secretary of the Department of Homeland Security Status Report due by 4/30/2018. Signed by Judge Jon S. Tigar on March 1, 2018. (wsn, COURT STAFF) (Filed on 3/1/2018)

1 ALEX G. TSE (CABN 152348)
Acting United States Attorney
2 SARA WINSLOW (DCBN 457643)
Chief, Civil Division
3 WENDY M. GARBERS (CABN 213208)
Assistant United States Attorney
4 DAVID A. PEREDA (CABN 237982)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
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San Francisco, California 94102-3495
Telephone: [phone]
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FAX: [phone]
[e-mail]
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Attorneys for Defendant SECRETARY OF
9 THE DEPARTMENT OF HOMELAND
SECURITY
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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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K. H., C.V., W.L., J.M., JEFFREY BOYER,
BRIAN PIEROG, DONNA BAXTER,
RICHARD DEVIVO, and GARY
MCCONAGHY, on behalf of themselves and
those similarly situated,

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STIPULATION AND [PROPOSED] ORDER RE
SETTLEMENT AND VACATING DEADLINES
The Honorable Jon S. Tigar

Plaintiffs,

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Case No. 15-cv-02740 JST

v.
THE SECRETARY OF THE DEPARTMENT
OF HOMELAND SECURITY,
Defendant.

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STIPULATION
WHEREAS, on February 23, 2018, the parties participated in an all-day settlement conference led

25 by Magistrate Judge Laurel Beeler;
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WHEREAS, the parties reached a global settlement of the action subject to necessary governmental

27 approvals;
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WHEREAS, the settlement was put on the record;
STIPULATION AND [PROPOSED] ORDER RE SETTLEMENT AND VACATING DEADLINES
NO. 15-CV-02740 JST

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WHEREAS, the parties also contemplate preparing a written settlement agreement, which will be

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2 signed by all opt-in plaintiffs; and
WHEREAS, the parties estimate that it will take about 60 days to document the settlement and

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4 obtain the requisite governmental approvals;
IT IS HEREBY STIPULATED, by the parties to the above-captioned action, by and through their

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6 respective counsel of record, that:
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1. All deadlines and other dates currently on calendar are vacated; and

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2. Within 60 days, the parties will file a joint statement reporting on the status of finalizing the

9 settlement.
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DATED: February 28, 2018

Respectfully submitted,

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ALEX G. TSE
Acting United States Attorney

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/s/ Wendy M. Garbers
WENDY M. GARBERS
Assistant United States Attorney
Attorneys for Defendant

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16 DATED: February 28, 2018

CLARK HILL PLLC

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/s/ Nicholas M. Wieczorek *
NICHOLAS M. WIECZOREK
Attorneys for Plaintiffs

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19 *In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of perjury
that all signatories have concurred in the filing of this document.
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[PROPOSED] ORDER

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Pursuant to the parties’ settlement and stipulation, IT IS SO ORDERED.

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25 Dated:

March 1, 2018

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THE HONORABLE JON S. TIGAR
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STIPULATION AND [PROPOSED] ORDER RE SETTLEMENT AND VACATING DEADLINES
NO. 15-CV-02740 JST

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