Kirola et al v. City & County of San Francisco, The et al

Filing 661

ORDER by Judge Saundra Brown Armstrong Granting 660 Stipulation. (ndr, COURT STAFF) (Filed on 4/7/2014)

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Guy B. Wallace, State Bar No. 176151
Mark T. Johnson, State Bar No. 76904
SCHNEIDER WALLACE
COTTRELL KONECKY LLP
180 Montgomery Street, Suite 2000
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
James C. Sturdevant, State Bar No. 94551
THE STURDEVANT LAW FIRM
A Professional Corporation
354 Pine Street, Fourth Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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IVANA KIROLA, et al.,
Plaintiffs,

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vs.
THE CITY AND COUNTY OF SAN
FRANCISCO (“the CITY”), et al.;

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No. 4:07-CV-03685 SBA
CLASS ACTION
STIPULATION ON REQUEST FOR
EXTENSION OF TIME TO FILE JOINT
STATEMENT RE FURTHER PROCEEDINGS;
[PROPOSED] ORDER

Defendants.

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STIPULATION ON REQUEST FOR EXTENSION OF TIME TO FILE JOINT STATEMENT RE: FURTHER PROCEEDINGS;
[PROPOSED] ORDER
KIROLA ET AL. V. CITY AND COUNTY OF SAN FRANCISCO, ET AL., CASE NO. 4:07-CV-03685 SBA

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STIPULATION

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WHEREAS, by its Order of March 20, 2014, (Dkt. No. 659 – “the Order), this Court

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directed the parties to meet and confer and to file a joint statement regarding what, if any,

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additional briefing, submission of evidence and/or further court proceedings are necessary and

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appropriate for the final resolution of this action and to further meet and confer regarding potential,

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further motion practice or supplemental briefing on specific issues;

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WHEREAS, the Order required that the parties’ Joint Statement Re Further Proceedings
described above be filed by no later than April 11, 2014;

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WHEREAS, the parties promptly engaged in the meet and confer process required by the

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Order by engaging in comprehensive discussions on Friday, March 21 and Monday, March 22,

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2014. During those discussions each side described its positions, to the extent they were then

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developed, on each of the issues raised by the Order;

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WHEREAS, following the meet and confer process, it was agreed by the parties that the
City would prepare an initial draft of the Joint Statement, including those sections setting forth its
positions that differed from Plaintiffs’ positions, after which Plaintiffs would review and add to the
draft;
WHEREAS, counsel for the City were not able to complete the preparation and internal
review of an initial draft of the Joint Stipulation until April 7, 2014 due, in part, to the need to
complete work on an appellate brief that was due on April 1, 2014 in the matter of Anderson v.
City & County of San Francisco, Cal. Court App., First Appellate Dist., Case No. A138856.
WHEREAS, Mark Johnson, one of the two attorneys for Plaintiffs involved in the meet and
confer process and the preparation Plaintiffs’ portion of the Joint Statement, will be out of the
office for personal reasons and unable to devote any time to this project for the period of April 9
through April 11, 2014;
WHEREAS, the parties anticipate that further meet and confer efforts may be appropriate

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once a draft of the Joint Statement containing the positions of both parties has been prepared;
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STIPULATION ON REQUEST FOR EXTENSION OF TIME TO FILE JOINT STATEMENT RE: FURTHER PROCEEDINGS;
[PROPOSED] ORDER
KIROLA ET AL. V. CITY AND COUNTY OF SAN FRANCISCO, ET AL., CASE NO. 4:07-CV-03685 SBA
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WHEREAS, Plaintiffs have proposed, and Defendants do not oppose, a one week extension
of the deadline for filing the Joint Statement, to and including April 18, 2014;
THEREFORE, it is hereby stipulated, subject to the approval of the Court, that date by

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which the Joint Statement Re: Further Proceedings be extended by one week, so that it is filed by

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no later than April 18, 2014.

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IT IS SO STIPULATED.

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Dated: April 7, 2014

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SCHNEIDER WALLACE
COTTRELL KONECKY LLP
/s/
MARK JOHNSON
Counsel for Plaintiffs

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Dated: April 7, 2014

OFFICE OF THE CITY ATTORNEY
/s/
_
JAMES M. EMERY
Counsel for Defendants

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ORDER
Pursuant to the foregoing stipulation of the parties, IT IS HEREBY ORDERED that the

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Joint Stipulation Re: Further Proceedings that is the subject of the Court’s Order of March 20,
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2014 (Dkt. No. 659), which was previously required to be filed by no later than April 11, 2014,
may be filed by no later than April 18, 2014.
All other terms of the Court’s Order of March 20, 2014 are unchanged.
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DATED: April ___, 2014

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_______________________________________

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SAUNDRA BROWN ARMSTRONG
United States District Judge

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STIPULATION ON REQUEST FOR EXTENSION OF TIME TO FILE JOINT STATEMENT RE: FURTHER PROCEEDINGS;
[PROPOSED] ORDER
KIROLA ET AL. V. CITY AND COUNTY OF SAN FRANCISCO, ET AL., CASE NO. 4:07-CV-03685 SBA
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