Los Angeles Times Communications LLC v. Kernan, et al.

Filing 35

STIPULATION AND ORDER Scheduling Case Management Conference. Case Management Statement due by 2/7/2019. Initial Case Management Conference set for 2/14/2019 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor. Signed by Judge Richard Seeborg on 12/18/18. (cl, COURT STAFF) (Filed on 12/18/2018)

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KEKER, VAN NEST & PETERS LLP
AJAY S. KRISHNAN - # 222476
[e-mail]
BENJAMIN BERKOWITZ - # 244441
[e-mail]
CHRISTOPHER S. SUN - # 308945
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
415 391 5400
Facsimile:
415 397 7188
ACLU FOUNDATION OF NORTHERN
CALIFORNIA
ALAN SCHLOSSER - # 49957
[e-mail]
SHILPI AGARWAL - # 270749
[e-mail]
KATHLEEN GUNERATNE - # 250751
[e-mail]
39 Drumm Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

DAVIS WRIGHT TREMAINE LLP
THOMAS R. BURKE - #141930
505 Montgomery St. Suite 800
San Francisco, CA 94111
Telephone: [phone]
Attorneys for Plaintiffs KQED, Inc. and
Los Angeles Times Communications LLC

JEFFREY GLASSER - # 252596
Los Angeles Times Communications LLC
202 West 1st Street
Los Angeles, CA 90012
Telephone: [phone]
Attorney for Plaintiff Los Angeles Times
Communications LLC

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Attorneys for Plaintiffs
San Francisco Progressive Media Center

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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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LOS ANGELES TIMES
COMMUNICATIONS LLC, KQED, INC.,
SAN FRANCISCO PROGRESSIVE
MEDIA CENTER,

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Case No. 3:18-cv-02146-RS
STIPULATION AND [PROPOSED]
ORDER SCHEDULING CASE
MANAGEMENT CONFERENCE

Plaintiffs,
Courtroom: 3, 17th Floor
Judge:
Hon. Richard Seeborg

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v.
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RALPH DIAZ, ACTING SECRETARY OF
THE CALIFORNIA DEPARTMENT OF
CORRECTIONS AND
REHABILITATION, RONALD DAVIS,
WARDEN OF THE CALIFORNIA STATE
PRISON AT SAN QUENTIN,

Date Filed: April 11, 2018
Trial Date: Not Yet Set

Defendants.

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STIPULATION AND [PROPOSED] ORDER SCHEDULING CASE MANAGEMENT CONFERENCE
Case No. 3:18-cv-02146-RS
1311120

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Pursuant to Federal Rule of Civil Procedure 16 and Civil Local Rules 16 and 7-12,

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Plaintiffs Los Angeles Times Communications LLC; KQED, Inc.; and San Francisco Progressive

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Media Center, and Defendants Ralph Diaz and Ronald Davis, by and through their respective

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counsel, enter into the following stipulation requesting that the Court schedule a case

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management conference for February 14, 2019. The parties hereby stipulate as follows:

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1.

On April 11, 2018, Plaintiffs filed their Complaint in this action;

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2.

On May 3, 2018, Defendants responded to the Complaint by filing a Partial

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Motion to Dismiss;

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On August 17, 2018, the Court issued an order denying Defendants’ Partial

Motion to Dismiss;

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4.

On August 31, 2018, Defendants filed an Answer to the Complaint;

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5.

The Court has not scheduled a case management conference or issued a scheduling

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order in this matter;

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and expeditious litigation of this case;

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The parties agree that a case management conference would facilitate the efficient

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On November 14, 2018, Plaintiffs requested that Defendants stipulate to a joint

request asking the Court to schedule a case management conference in the above-entitled matter.

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8.

Defendants requested that a case management conference be set on a mutually

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agreeable date after the holiday season in late January or early February. Plaintiffs provided two

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dates, January 24, 2019 and February 14, 2019, and Defendants chose February 14, 2019.

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9.

The parties stipulate and jointly request that the Court schedule a case

management conference in the above-captioned matter for February 14, 2019.

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SO STIPULATED AND AGREED.

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STIPULATION AND [PROPOSED] ORDER SCHEDULING CASE MANAGEMENT CONFERENCE
Case No. 3:18-cv-02146-RS
1311120

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Dated: December 18, 2018

KEKER, VAN NEST & PETERS LLP

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By:

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Attorneys for Plaintiffs
San Francisco Progressive Media Center

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/s/ Ajay S. Krishnan
AJAY S. KRISHNAN

Dated: December 18, 2018

DAVID WRIGHT TREMAINE LLP

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By:
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/s/ Thomas R. Burke
THOMAS R. BURKE
Attorneys for Plaintiffs KQED, Inc. and Los
Angeles Times Communications LLC

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Dated: December 17, 2018

By:

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/s/ Jay M. Goldman
JAY M. GOLDMAN
Supervising Deputy Attorney General
Attorneys for Defendants Ralph Diaz and
Ronald Davis

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ATTESTATION

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I, Ajay S. Krishnan, am the ECF user whose Login and Password authorized the filing of

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this document. Under Civil Local Rule 5-1(i)(3), I attest that the other above signatories have
concurred in the filing of this document.
Dated: December 18, 2018

By:

/s/ Ajay S. Krishnan
AJAY S. KRISHNAN

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STIPULATION AND [PROPOSED] ORDER SCHEDULING CASE MANAGEMENT CONFERENCE
Case No. 3:18-cv-02146-RS
1311120

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[PROPOSED] ORDER

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The parties’ stipulation having been considered, and good cause appearing therefor, a case
management conference in this matter is scheduled for _______________________.
February 14, 2019 at 10:00 am

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IT IS SO ORDERED.

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Dated: 12/18/18

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By: ___________________________________
HON. RICHARD SEEBORG
UNITED STATES DISTRICT COURT

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STIPULATION AND [PROPOSED] ORDER SCHEDULING CASE MANAGEMENT CONFERENCE
Case No. 3:18-cv-02146-RS
1311120