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)

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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 4 450 Golden Gate Avenue, Box 36055 5 San Francisco, California 94102-3495 Telephone: (415) 436-6475 6 FAX: (415) 436-7234 wendy.garbers@usdoj.gov 7 Attorneys for Defendant SECRETARY OF THE 8 DEPARTMENT OF HOMELAND SECURITY 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 15 16 17 18 SAI, ) ) Plaintiff, ) ) v. ) ) COVENANT AVIATION SECURITY, LLC, et ) al., ) Defendants. ) ) No. 16-cv-01024 JST STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC The Honorable Jon S. Tigar 19 20 WHEREAS, this matter is currently stayed for all purposes other than ADR until January 2, 2019 21 (ECF 237); 22 WHEREAS, on December 13, 2018, the parties participated in an all-day settlement conference 23 with the assistance of Magistrate Judge Sallie Kim; 24 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; 26 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; 28 30 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 1 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, 2 3 2019; 4 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: 6 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 8 2. The further case management conference also be continued until after March 4, 2019. 9 10 DATED: December 17, 2018 Respectfully submitted, 11 ALEX G. TSE United States Attorney 12 /s/ Wendy M. Garbers WENDY M. GARBERS Assistant United States Attorney 13 14 15 16 DATED: December 17, 2018 CODDINGTON, HICKS & DANFORTH 17 18 /s/ Richard G. Grotch* RICHARD G. GROTCH 19 Attorneys for Defendant COVENANT AVIATION SECURITY, LLC 20 21 22 23 DATED: December 17, 2018 BAKER BOTTS LLP 24 25 26 /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. 30 STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC No. 16-cv-01024 JST 2 1 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, it is hereby ordered that they stay previously entered in this 3 4 5 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. 6 7 Dated: December 18, 2018 8 9 10 HONORABLE JON S. TIGAR United States District Judge 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30 STIPULATION AND [PROPOSED] ORDER RE STAY PENDING ADR AND FURTHER CMC No. 16-cv-01024 JST 3

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