Doe et al v. City of Novato et al

Filing 42

STIPULATION AND ORDER re 41 STIPULATION WITH PROPOSED ORDER STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEADLINE FOR COMPLETION OF ADR PROCESS filed by City of Novato, Oliver Collins. Signed by Judge Jon S. Tigar on October 24, 2016. (wsn, COURT STAFF) (Filed on 10/24/2016)

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1 2 3 4 5 Suzanne Solomon, Bar No. 169005 ssolomon@lcwlegal.com Arlin Kachalia, Bar No. 193752 akachalia@lcwlegal.com LIEBERT CASSIDY WHITMORE A Professional Law Corporation 135 Main Street, 7th Floor San Francisco, California 94105 Telephone: 415.512.3000 Facsimile: 415.856.0306 6 7 8 9 10 11 12 Attorneys for Defendants CITY OF NOVATO and LT. OLIVER COLLINS Mary Shea Hagebols, Bar No. 113222 mary@shelaw.com SHEA LAW OFFICES 1814 Franklin Street, Suite 800 Oakland, CA 94612 Telephone: 510.208.4422 Facsimile: 510.520.9407 Attorneys for Plaintiffs JEFFREY A. AMES and SASHA M. D’AMICO 13 LIEBERT CASSIDY WHITMORE A Professional Law Corporation 135 Main Street, 7th Floor San Francisco, California 94105 14 15 16 17 Fulvio F. Cajina, Bar No. 289126 fulvio@cajinalaw.com 311 Oak Street, Suite 108 Oakland, CA 94607 Telephone: 415.601.0779 Facsimile: 510.225.2636 Attorney for Plaintiffs JEFFREY A. AMES and SASHA M. D’AMICO 18 19 UNITED STATES DISTRICT COURT 20 NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO 21 22 JEFFREY A. AMES and SASHA M. D’AMICO, 23 24 25 Plaintiffs, v. CITY OF NOVATO; LT. OLIVER COLLINS, et al., Case No.: 3:16-cv-02590-JST Complaint Filed: May 13, 2016 FAC Filed: May 16, 2016 STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE DEADLINE FOR COMPLETION OF ADR PROCESS 26 Defendants. 27 28 30 31 CASE No.: 3:16-cv-02590-JST STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE ADR DEADLINE 7949510.5 NO029-023 1 Plaintiffs Jeffrey Ames and Sasha D’Amico (“Plaintiffs”) and Defendants City of Novato 2 and Lt. Oliver Collins (collectively, “Defendants”), by and through their respective counsel of 3 record, hereby stipulate as follows for consideration and approval by the Court: 4 5 6 A. WHEREAS, Plaintiffs filed a First Amended Complaint for Damages on May 16, 2016 and served Defendants on May 20, 2016; B. WHEREAS, on May 31, 2016, the parties agreed and stipulated to extending 7 Defendants’ time to respond to Plaintiffs’ First Amended Complaint from June 10, 8 2016 to July 6, 2016; 9 10 11 12 13 LIEBERT CASSIDY WHITMORE A Professional Law Corporation 135 Main Street, 7th Floor San Francisco, California 94105 14 15 C. WHEREAS, on July 6, 2016, Defendants City of Novato and Lt. Oliver Collins filed a Motion to Dismiss Portions of Plaintiffs’ First Amended Complaint; D. WHEREAS, on July 6, 2016, the Court scheduled a Case Management Conference for September 14, 2016. E. WHEREAS, on July 14, 2016, Defendants City of Novato and Lt. Oliver Collins filed a Motion to Sever Plaintiff D’Amico’s Claims into a Separate Action; F. WHEREAS, on July 19, 2016, the parties agreed and stipulated, and this Court 16 approved, that the hearing on Defendants’ Motion to Dismiss Portions of Plaintiffs’ 17 First Amended Complaint and Motion to Sever Plaintiff D’Amico’s Claims into 18 Separate Action be continued to September 1, 2016 at 2:00 p.m. and to extend briefing 19 dates.; 20 21 G. WHEREAS, Fulvio Cajina associated in as co-counsel for Plaintiffs on August 10, 2016; 22 H. WHEREAS, on August 31, 2016, the parties agreed and stipulated, and this Court 23 approved, to continue the case management conference, the deadline for filing the 24 ADR stipulation/notice for phone conference, and related dates; 25 26 27 28 30 31 I. WHEREAS, on September 14, 2016, the parties agreed and stipulated to Mediation as their preferred ADR process; J. WHEREAS, on September 19, 2016, this Court approved, and ordered, completion of Mediation within 90 days of the order, or by December 19, 2016; 1 CASE No.: 3:16-cv-02590-JST STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE ADR DEADLINE 7949510.5 NO029-023 1 K. WHEREAS, the parties appeared before the Court at the October 19, 2016, case 2 management conference, and represented to the court that they have agreed to use a 3 private mediator who is not available until March 2017. This Court approved the 4 parties’ filing of this stipulation to extend the mediation deadline. 5 NOW THEREFORE, the Plaintiffs and Defendants stipulate, by and through their counsel and 6 pursuant to Court approval, that: 7 1. The continued deadline to complete ADR (mediation) in this matter is on or before 8 9 10 March 31, 2017. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: October 24, 2016 11 LIEBERT CASSIDY WHITMORE By: 12 13 LIEBERT CASSIDY WHITMORE A Professional Law Corporation 135 Main Street, 7th Floor San Francisco, California 94105 14 Dated: October 24, 2016 15 SHEA LAW OFFICES By: 16 17 18 Dated: October 24, 2016 /s/ Mary Shea Hagebols Mary Shea Hagebols Attorneys for Plaintiffs JEFFREY A. AMES and SASHA M. D’AMICO LAW OFFICE OF FULVIO F. CAJINA By: 19 /s/ Suzanne Solomon Suzanne Solomon Arlin Kachalia Attorneys for Defendants CITY OF NOVATO and LT. OLIVER COLLINS 20 /s/ Fulvio F. Cajina Fulvio F. Cajina Attorneys for Plaintiffs JEFFREY A. AMES and SASHA M. D’AMICO 21 [PROPOSED] ORDER 22 1. The parties have agreed to private mediation, and shall to hold the ADR session on 23 or before March 31, 2017. 24 PURSUANT TO STIPULATION, IT IS SO ORDERED. 25 26 24 Dated: October ___, 2016 27 The Honorable Jon S. Tigar United States District Judge 28 30 31 2 CASE No.: 3:16-cv-02590-JST STIPULATION AND [PROPOSED] ORDER TO CONTINUE THE ADR DEADLINE 7949510.5 NO029-023

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