Sonoma County Association of Retired Employees v. Sonoma County

Filing 188

STIPULATION AND ORDER Extending Time And Setting Case Schedule. Fact Discovery Cut-off 6/23/2015. Expert Discovery Cut-off 08/14/2015. Set/Reset Deadlines as to 166 MOTION for Summary Judgment. Opposition/Cross-motion due by 7/23/2015. SCA RE's Reply due by 9/8/2015. County's Reply due by 10/1/2015. Motion Hearing set for 10/29/2015 02:00 PM in Courtroom 2, 4th Floor, Oakland before Hon. Claudia Wilken. Signed by Judge Claudia Wilken on 06/16/2015. (tmiS, COURT STAFF) (Filed on 6/16/2015)

1 LEWIS, FEINBERG, LEE & JACKSON, P.C.
JEFFREY LEWIS, SBN 066587
2 [e-mail]
DARIN D. RANAHAN, SBN 273532
3 [e-mail]
LINDA LAM, SBN 301461
4 [e-mail]
476 9th Street
5 Oakland, CA 94607
Telephone:
[phone]
6 Facsimile:
[phone]
7 Attorneys for Plaintiff
SONOMA COUNTY ASSOCIATION OF RETIRED EMPLOYEES
8
9 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
10 [e-mail]
BATYA F. FORSYTH, SBN 192396
11 [e-mail]
STEPHEN B. PECK, SBN 72214
12 [e-mail]
425 Market Street, 26th Floor
13 San Francisco, California 94105
Telephone:
[phone]
[phone]
14 Facsimile:
15 Attorneys for Defendant COUNTY OF SONOMA
16
17

UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

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20 SONOMA COUNTY ASSOCIATION OF
RETIRED EMPLOYEES,
21
Plaintiff,
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v.
23
SONOMA COUNTY,
24
Defendant.
25

CASE NO. CV 09-4432 CW
MODIFIED
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME AND
SETTING CASE SCHEDULE
Judge: Hon. Claudia Wilken

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27
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11300604.3

STIPULATION AND [PROPOSED] ORDER EXTENDING TIME AND SETTING CASE SCHEDULE

1

Plaintiff Sonoma County Association of Retired Employees (“SCARE” or "Plaintiff") and

2 Defendant County of Sonoma (the “County” or "Defendant") (collectively the “Parties”), by and
3 through their respective counsel of record, hereby enter into the following stipulated request for an
4 order extending time pursuant to Local Rule 6-2 and related orders.
5

WHEREAS, Plaintiff filed a Motion for Partial Summary Judgment on May 28, 2015;

6

WHEREAS, the current summary judgment motion ("dispositive motion" or "dispositive

7 motions") and case schedule (ECF 163) provides that Defendant’s opposition to Plaintiff's
8 dispositive motion its and dispositive cross-motion are due on June 25, 2015, Plaintiff’s reply in
9 support of its dispositive motion and/or opposition to Defendant’s dispositive cross-motion are
10 due July 9, 2015, Defendant’s reply in support of its dispositive cross-motion is due July 23, 2015,
11 the Parties’ dispositive motions are to be heard 14 days after Defendant's reply, or as soon
12 thereafter as the Court schedules a hearing, the fact discovery cut-off is June 23, 2015, and the
13 expert discovery cut-off is July 7, 2015;
14

WHEREAS, the Parties wish to establish the below case schedule to allow additional time

15 to prepare dispositive motion papers, to facilitate the completion of limited remaining discovery,
16 and to have a hearing on a date available to both lead attorneys;
17

THEREFORE, IT IS STIPULATED THAT:

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The current case schedule shall be modified as follows:

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Event

Deadline

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Fact Discovery Cut-off
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25
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June 23, 2015, except (i) Defendant may take the
depositions of Bill Robotka and Nick Velichinsky as
agreed by Plaintiff, (ii) Plaintiff may take the deposition
of Dania Torres Wong as agreed by Defendant, (iii)
Defendant may re-open the deposition of Ray Myers as
agreed by Plaintiff, and (iv) discovery motions by either
Plaintiff or Defendant limited to challenging (a) the
withholding of documents solely on the grounds
identified in privilege logs, including but not limited to
attorney-client privilege, work product, deliberative
process privilege, closed session, mediation privilege,
and Evidence Code § 1152, and (b) assertions of
privilege at the depositions identified above in items (i)
through (iii), including in objections to any
accompanying subpoenas.

28
11300604.3

CV 09-4432 CW
-1STIPULATION AND [PROPOSED] ORDER EXTENDING TIME AND SETTING CASE SCHEDULE

1

Event

Deadline

2
The fact discovery cut-off date for the completion of
the Robotka, Velichinsky, Myers and Wong depositions
and the filing of any motion pursuant to item (iv) is
July 21, 2015.

3
4
5

Expert Discovery Cut-off

August 14, 2015

6

County's dispositive motion and
opposition to Plaintiff's dispositive
motion Due [35 page brief]

July 23, 2015

SCARE's Reply to County
dispositive motion Due [25 page
brief]

September 8, 2015

County's Reply to Plaintiff's
opposition to County's dispositive
motion Due [15 page brief]

October 1, 2015

7
8
9
10
11
12
13

Hearing on Dispositive Motions and October 15, 2015 or as soon thereafter as the Court
Case Management Conference
schedules a hearing.

14
15 DATED: June 15, 2015

LEWIS, FEINBERG, LEE & JACKSON, P.C.

16
By:/s/ Darin Ranahan
JEFFREY LEWIS
DARIN RANAHAN
LINDA LAM
Attorneys for Plaintiff
SONOMA COUNTY ASSOCIATION OF
RETIRED EMPLOYEES

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18
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20
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DATED: June 15, 2015

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By:/s/ Batya F. Forsyth
RAYMOND F. LYNCH
BATYA F. FORSYTH
STEPHEN B. PECK
Attorneys for Defendant
COUNTY OF SONOMA

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24
25
26
27

HANSON BRIDGETT LLP

This Court, having considered the Parties’ stipulated request for the above modified case
schedule, hereby GRANTS said request. The case schedule shall be:

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11300604.3

-2STIPULATION AND [PROPOSED] ORDER EXTENDING TIME

CV 09-4432 CW

1
2

Event
Fact Discovery Cut-off

3
4
5
6
7
8
9
10

Deadline
June 23, 2015, except (i) Defendant may take the
depositions of Bill Robotka and Nick Velichinsky as
agreed by Plaintiff, (ii) Plaintiff may take the deposition
of Dania Torres Wong as agreed by Defendant, (iii)
Defendant may re-open the deposition of Ray Myers as
agreed by Plaintiff, and (iv) discovery motions by either
Plaintiff or Defendant limited to challenging (a) the
withholding of documents solely on the grounds
identified in privilege logs, including but not limited to
attorney-client privilege, work product, deliberative
process privilege, closed session, mediation privilege,
and Evidence Code § 1152, and (b) assertions of
privilege at the depositions identified above in items (i)
through (iii), including in objections to any
accompanying subpoenas.
The fact discovery cut-off date for the completion of
the Robotka, Velichinsky, Myers and Wong depositions
and the filing of any motion pursuant to item (iv) is
July 21, 2015.

11
12
Expert Discovery Cut-off

August 14, 2015

County's dispositive motion and
opposition to Plaintiff's dispositive
motion Due [35 page brief]

July 23, 2015

SCARE's Reply to County's
dispositive motion Due [25 page
brief]

September 8, 2015

County's Reply to Plaintiff's
opposition to County's dispositive
motion Due [15 page brief]

October 1, 2015

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14
15
16
17
18
19
20

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Hearing on Dispositive Motions and October 15, 2015 or as soon thereafter as the Court
Case Management Conference
schedules a hearing.

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ISTRIC
ES D
TC
AT
T

RT
U
O

06/16
Dated: _________________, 2015

S

THE HONORABLE CLAUDIA WILKEN
Judge of the UnitedDERED District Court
States
SO OR
NO

26

ilken

laudia W

Judge C

RT

27

H

ER

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11300604.3

R NIA

IT IS
DIFIED
AS MO

FO

25

LI

24

A

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AS
PURSUANT TO STIPULATION, IT IS SO ORDERED. MODIFIED.

UNIT
ED

22

N

F
D IS T IC T O
R

C

-3STIPULATION AND [PROPOSED] ORDER EXTENDING TIME

CV 09-4432 CW