City Of San Jose et al v. Ross et al

Filing 89

STIPULATION AND ORDER RE 88 TO CASE SCHEDULE AS MODIFIED BY THE COURT. Bench Trial set for 1/7/2019 at 09:00 AM before Judge Richard Seeborg. Pretrial Conference set for 1/2/2019 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Judge Richard Seeborg on 8/30/18. (cl, COURT STAFF) (Filed on 8/30/2018)

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MANATT, PHELPS & PHILLIPS, LLP
JOHN F. LIBBY (Bar No. CA 128207)
E-mail: [e-mail]
JOHN W. MCGUINNESS (Bar No. CA 277322)
E-mail: [e-mail]
EMIL PETROSSIAN (Bar No. CA 264222)
E-mail: [e-mail]
11355 West Olympic Boulevard
Los Angeles, California 90064
Telephone: [phone]
Facsimile: [phone]
LAWYERS’ COMMITTEE FOR CIVIL RIGHTS UNDER LAW
KRISTEN CLARKE (Pro Hac Vice Application Forthcoming)
Email: [e-mail]
JON M. GREENBAUM (Bar No. CA 166733)
E-mail: [e-mail]
EZRA D. ROSENBERG (Admitted Pro Hac Vice)
E-mail: [e-mail]
DORIAN L. SPENCE (Admitted Pro Hac Vice)
E-mail: [e-mail]
1401 New York Avenue NW, Suite 400
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
CITY OF SAN JOSE and BLACK ALLIANCE FOR JUST IMMIGRATION
[Additional Counsel Listed on Signature Page]

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
CITY OF SAN JOSE, a municipal corporation;
Case No. 3:18-cv-2279-RS
and BLACK ALLIANCE FOR JUST
IMMIGRATION, a California nonprofit
STIPULATION TO CASE SCHEDULE
corporation,
AND [PROPOSED] ORDER AS MODIFIED
BY THE COURT
Plaintiffs,
Dept.:
Judge:

vs.
WILBUR L. ROSS, JR., in his official capacity
as Secretary of the U.S. Department of
Commerce; U.S. DEPARTMENT OF
COMMERCE; RON JARMIN, in his official
capacity as Acting Director of the U.S. Census
Bureau; U.S. CENSUS BUREAU,

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Hon. Richard G. Seeborg

Trial Date: January 7, 2019
Action Filed: April 17, 2018

Defendants.

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M ANATT , P HELPS &
P HILLIPS , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

STIPULATION AND [PROPOSED] ORDER – CASE NO. 3:18-cv-2279-RS

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Plaintiffs City of San Jose and Black Alliance for Just Immigration (“Plaintiffs”) and

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Defendants Wilbur L. Ross, Jr., U.S. Department of Commerce, Ron Jarmin, and U.S. Census

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Bureau (collectively, “Defendants,” and together with Plaintiffs, the “Parties”) hereby stipulate as

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follows:

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Based on the agreement of the Parties as approved by the Court, and pursuant to the

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Court’s request at the August 10, 2018 hearing, the following is the schedule for the above-

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captioned case.

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Defendants’ responses to Plaintiffs’ requests for production of documents were

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served on August 24, 2018. Subject to approval by the Court, the Parties have

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agreed to extend the due date for Defendants to serve their initial disclosures from

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August 24, 2018, to August 31, 2018.

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The Parties shall designate expert witnesses by September 19, 2018.

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The Parties shall designate rebuttal witnesses by October 3, 2018.

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Discovery shall close on October 11, 2018.

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Any dispositive motions shall be heard on or before December 7, 2018.

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A joint pretrial conference shall be held on January 3, 2019.

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Trial shall begin on January 7, 2019.

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IT IS SO STIPULATED.

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M ANATT , P HELPS &
P HILLIPS , LLP

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ATTO RNEY S AT LAW

STIPULATION AND [PROPOSED] ORDER– CASE NO. 3:18-cv-2279-RS

LOS A NG EL ES

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Respectfully submitted,
Dated:

August 29, 2018

MANATT, PHELPS & PHILLIPS, LLP

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By: /s/ John F. Libby
John F. Libby
John W. McGuinness
Emil Petrossian
11355 West Olympic Boulevard
Los Angeles, California 90064
Telephone: [phone]
Facsimile: [phone]
LAWYERS’ COMMITTEE FOR CIVIL
RIGHTS UNDER LAW
Kristen Clarke
Jon M. Greenbaum
Ezra D. Rosenberg
Dorian L. Spence
1401 New York Avenue NW, Suite 400
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
PUBLIC COUNSEL
Mark Rosenbaum
610 South Ardmore Avenue
Los Angeles, California 90005
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
CITY OF SAN JOSE
Richard Doyle, City Attorney
Nora Frimann, Assistant City Attorney
Office of the City Attorney
200 East Santa Clara Street, 16th Floor
San José, California 95113-1905
Telephone Number: [phone]
Facsimile Number: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiffs
CITY OF SAN JOSE and BLACK ALLIANCE FOR
JUST IMMIGRATION

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M ANATT , P HELPS &
P HILLIPS , LLP

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ATTO RNEY S AT LAW

STIPULATION AND [PROPOSED] ORDER– CASE NO. 3:18-cv-2279-RS

LOS A NG EL ES

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Dated: August 29, 2018

CHAD A. READLER
Acting Assistant Attorney General
BRETT A. SHUMATE
Deputy Assistant Attorney General
CARLOTTA P. WELLS
Assistant Branch Director
/s/ Carol Federighi
KATE BAILEY
STEPHEN EHRLICH
CAROL FEDERIGHI
Trial Attorneys
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue NW
Washington, DC 20530
Phone: [phone]
Email: [e-mail]
Attorneys for Defendants

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M ANATT , P HELPS &
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ATTO RNEY S AT LAW

STIPULATION AND [PROPOSED] ORDER– CASE NO. 3:18-cv-2279-RS

LOS A NG EL ES

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FILER’S ATTESTATION
Pursuant to Civil Local Rule 5-1(i)(3), regarding signatures, I hereby attest that

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concurrence in the filing of this document has been obtained from all signatories above.

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Dated: August 29, 2018

/s/ John F. Libby
JOHN F. LIBBY

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M ANATT , P HELPS &
P HILLIPS , LLP

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ATTO RNEY S AT LAW

STIPULATION AND [PROPOSED] ORDER– CASE NO. 3:18-cv-2279-RS

LOS A NG EL ES

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ORDER
Based on the Parties’ Stipulation to Case Schedule, the schedule for the above-captioned
case shall be as follows:

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Defendants’ responses to Plaintiffs’ requests for production of documents were due

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(and were served) on August 24, 2018. Defendants’ initial disclosures shall be due

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on August 31, 2018.

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The Parties shall designate expert witnesses by September 19, 2018.

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The Parties shall designate rebuttal witnesses by October 3, 2018.

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Discovery shall close on October 11, 2018.

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Any dispositive motions shall be heard on or before December 7, 2018.
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A joint pretrial conference shall be held on January 3, 2019.

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Trial shall begin on January 7, 2019.

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IT IS SO ORDERED.

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DATED: _____________________
8/30/18

______________________________
HON. RICHARD SEEBORG
United States District Court Judge

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M ANATT , P HELPS &
P HILLIPS , LLP

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ATTO RNEY S AT LAW

STIPULATION AND [PROPOSED] ORDER– CASE NO. 3:18-cv-2279-RS

LOS A NG EL ES