Cardenas et al v. City Of Oakland et al

Filing 64

STIPULATION AND ORDER re 63 . STIPULATION WITH PROPOSED ORDER TO CONTINUE SETTLEMENT CONFERENCE filed by Victor Ramirez, Victor Fox, Michael Buckhout. Settlement conference statement to be lodged by 6/5/2018. Settlement Conference set for 6/15/2018 11:00 AM in Oakland, Courtroom 4, 3rd Floor. Signed by Magistrate Judge Kandis A. Westmore on 3/6/18. (sisS, COURT STAFF) (Filed on 3/6/2018)

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John L. Burris, State Bar No. 69888
Lateef Gray, State Bar No. 250055
James Cook, State Bar No. 300212
LAW OFFICES OF JOHN L. BURRIS
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]

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Attorney for Plaintiffs

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Michael C. Wenzel, State Bar No. 215388
Amy Leifur Halby, State Bar No. 287216
BERTRAND, FOX, ELLIOT,
OSMAN & WENZEL
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RITA CARDENAS, an individual, L.V., by and
through her guardian ad Litem Ruby Cardenas,
L.M., by and through her guardian ad Litem Ruby
Cardenas, and DAVID ORTIZ, an individual,

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Case No. 3:16-cv-05205 WHA
STIPULATION TO CONTINUE
SETTLEMENT CONFERENCE;
[PROPOSED] ORDER

Plaintiffs,
v.

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MICHAEL BUCKHOUT, individually and in
his capacity as a Deputy for the County of
Alameda Sheriff’s Department; VICTOR FOX,
individually and in his capacity as a Deputy for
the County of Alameda Sheriff’s Department;
VICTOR RAMIREZ, individually and in his
capacity as a Deputy for the County of Alameda
Sheriff’s Department; and DOES 1-25, inclusive,
individually, jointly and severally,
Defendants.
Hon. Kandis A. Westmore

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STIPULATION

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Defendants MICHAEL BUCKHOUT, VICTOR FOX, and VICTOR RAMIREZ and plaintiffs

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RITA CARDENAS, L.V. and L.M., by and through their Guardian Ad Litem RUBY CARDENAS, and

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DAVID ORTIZ, by and through their respective attorneys of record, hereby stipulate as follows:
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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE; [PROPOSED] ORDER

Cardenas, et al. v. County of Alameda, et al.; USDC Northern District of CA Case No.: 3:16-cv-05205

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1.

By telephone conference held on December 12, 2017, the Settlement Conference before

Magistrate Judge Kandis A. Westmore was set for April 6, 2018.
2.

The parties respectfully request that the Settlement Conference be rescheduled in order to

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permit the parties to engage in required pre-conference discovery which has been subject to repeated and

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ongoing delays due to the availability of the parties and counsel which has inhibited the scheduling of

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plaintiffs’ depositions. Absent a continuance, the parties will be unable to meaningfully participate in the

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conference.

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3.

For all the good cause stated above, the parties respectfully request this Court continue the

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Settlement Conference from April 6, 2018 to June 15, 2018. Defense counsel has contacted Courtroom

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Deputy Susan Imbriani and were advised of the availability of the new date, June 15, 2018, for the

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Settlement Conference.

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4.

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terms in an Order.

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The parties respectfully request that the Court approve this stipulation and incorporate its

IT IS SO STIPULATED.
Dated: March 5, 2018

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LAW OFFICES OF JOHN L. BURRIS
By:

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/s/ James Cook
James Cook
Attorney for Plaintiffs

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Dated: March 5, 2018

BERTRAND, FOX, ELLIOT, OSMAN & WENZEL
By:

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/s/ Michael Wenzel
Michael C. Wenzel
Amy Leifur Halby
Attorneys for Defendants MICHAEL BUCKHOUT,
VICTOR FOX and VICTOR RAMIREZ

ELECTRONIC CASE FILING ATTESTATION
I, Michael W. Wenzel, am the ECF user whose identification and password are being used to file
the foregoing document. Pursuant to Civil Local Rule 5.1(i), I hereby attest that concurrence in the filing
of these documents has been obtained from each of its signatories.
By:

/s/ Michael Wenzel
Michael C. Wenzel
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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE; [PROPOSED] ORDER

Cardenas, et al. v. County of Alameda, et al.; USDC Northern District of CA Case No.: 3:16-cv-05205

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ORDER

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GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the

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parties’ stipulation is hereby APPROVED. The Settlement Conference currently set for April 6, 2018 is

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continued to June 15, 2018 at 10:00 a.m.

11:00

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IT IS SO ORDERED.

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Dated:

3/6/18

KANDIS A. WESTMORE
United States Magistrate Judge

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STIPULATION TO CONTINUE SETTLEMENT CONFERENCE; [PROPOSED] ORDER

Cardenas, et al. v. County of Alameda, et al.; USDC Northern District of CA Case No.: 3:16-cv-05205