Sai v. Smith et al
Filing
241
STIPULATION AND ORDER re 240 STIPULATION WITH PROPOSED ORDER Re Stay Pending Further ADR filed by Kirstjen Nielsen. Case Management Statement due by 3/6/2019. Further Case Management Conference set for 3/13/2019 at 2:00 PM in San Francisco, Courtroom 9, 19th Floor. Signed by Judge Jon S. Tigar on December 18, 2018. (wsn, COURT STAFF) (Filed on 12/18/2018)
1 ALEX G. TSE (CABN 152348)
United States Attorney
2 SARA WINSLOW (DCBN 457643)
Chief, Civil Division
3 WENDY M. GARBERS (CABN 213208)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
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San Francisco, California 94102-3495
Telephone: (415) 436-6475
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FAX: (415) 436-7234
wendy.garbers@usdoj.gov
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Attorneys for Defendant SECRETARY OF THE
8 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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SAI,
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Plaintiff,
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v.
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COVENANT AVIATION SECURITY, LLC, et )
al.,
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Defendants.
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No. 16-cv-01024 JST
STIPULATION AND [PROPOSED] ORDER RE
STAY PENDING ADR AND FURTHER CMC
The Honorable Jon S. Tigar
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WHEREAS, this matter is currently stayed for all purposes other than ADR until January 2, 2019
21 (ECF 237);
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WHEREAS, on December 13, 2018, the parties participated in an all-day settlement conference
23 with the assistance of Magistrate Judge Sallie Kim;
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WHEREAS, at the December 13, 2018 settlement conference, plaintiff and defendant Covenant
25 Aviation Security, LLC, reached a settlement agreement, which they will reduce to writing;
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WHEREAS, plaintiff and the government did not reach a settlement at the conference. They did,
27 however, agree to some further steps, which have the potential to ultimately result in a settlement;
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WHEREAS, Judge Kim has agreed to further assist the parties with their ADR efforts and has
STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC
No. 16-cv-01024 JST
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1 scheduled a further telephone conference for January 29, 2019, at 9:00 a.m.;
WHEREAS, a further case management conference is currently scheduled herein for January 16,
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3 2019;
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IT IS HEREBY STIPULATED, by Plaintiff Sai, Defendant Secretary of the Department of
5 Homeland Security, and Defendant Covenant Aviation Security, LLC, that, subject to Court approval:
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1. The stay previously entered in this matter continue sixty more days, until March 4, 2019, in order
7 to accommodate the parties’ settlement discussions; and
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2. The further case management conference also be continued until after March 4, 2019.
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10 DATED: December 17, 2018
Respectfully submitted,
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ALEX G. TSE
United States Attorney
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/s/ Wendy M. Garbers
WENDY M. GARBERS
Assistant United States Attorney
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16 DATED: December 17, 2018
CODDINGTON, HICKS & DANFORTH
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/s/ Richard G. Grotch*
RICHARD G. GROTCH
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Attorneys for Defendant
COVENANT AVIATION
SECURITY, LLC
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23 DATED: December 17, 2018
BAKER BOTTS LLP
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/s/ Navi Singh Dhillon *
NAVI SINGH DHILLON
Attorneys for Plaintiff SAI
27 *In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of
28 perjury that all signatories have concurred in the filing of this document.
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STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC
No. 16-cv-01024 JST
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1
[PROPOSED] ORDER
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PURSUANT TO STIPULATION, it is hereby ordered that they stay previously entered in this
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matter continue until March 4, 2019. The January 16, 2019 CMC herein is hereby continued until
March 13
March 6
____________________, 2019 at 2:00, with statements due on ________________, 2019.
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Dated:
December 18, 2018
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HONORABLE JON S. TIGAR
United States District Judge
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STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC
No. 16-cv-01024 JST
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