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)
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?