Sonoma County Association of Retired Employees v. Sonoma County
Filing
99
ORDER by Judge Claudia Wilken Granting 98 Stipulation. (ndr, COURT STAFF) (Filed on 3/3/2014)
1 LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
JEFFREY LEWIS, SBN 066587
2 jlewis@lewisfeinberg.com
TERESA S. RENAKER, SBN 187800
3 trenaker@lewisfeinberg.com
ANDREW LAH, SBN 234580
4 alah@lewisfeinberg.com
DARIN D. RANAHAN, SBN 273532
5 dranahan@lewisfeinberg.com
476 9th Street
6 Oakland, CA 94607
Telephone: (510) 839-6824
7 Facsimile:
(510) 839-7839
8 Attorneys for Plaintiff
SONOMA COUNTY ASSOCIATION OF RETIRED EMPLOYEES
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10 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
11 rlynch@hansonbridgett.com
LAWRENCE M. CIRELLI, SBN 114710
12 lcirelli@hansonbridgett.com
STEPHEN B. PECK, SBN 72214
13 speck@hansonbridgett.com
JANE M. FEDDES, SBN 282117
14 jfeddes@hansonbridgett.com
425 Market Street, 26th Floor
15 San Francisco, California 94105
Telephone: (415) 777-3200
16 Facsimile:
(415) 541-9366
17 Attorneys for COUNTY OF SONOMA
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19
UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION
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22 SONOMA COUNTY ASSOCIATION OF
RETIRED EMPLOYEES,
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Plaintiff,
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v.
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SONOMA COUNTY,
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Defendant.
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CASE NO. CV 09-4432 CW
STIPULATION AND ORDER RE CASE
SCHEDULE
Judge: Hon. Claudia Wilken
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6000978.1
CV 09-4432 CW
STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
1
Plaintiff Sonoma County Association of Retired Employees (“Plaintiff”) and
2 Defendant County of Sonoma (“Defendant”) (collectively the "Parties"), by and through
3 their respective counsel of record, hereby stipulate to the following schedule and request
4 that the Court issue an Order regarding the case schedule.
5
WHEREAS, on January 10, 2014, the Court issued its Order granting in part, and
6 denying in part, Defendant’s motion to dismiss (Dkt. No. 96);
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WHEREAS, prior to the Court’s order granting in part Defendant’s motion to
8 dismiss, the Parties stipulated to a number of case deadlines based on the anticipated
9 filing of Defendant’s answer, including a dispositive motion briefing schedule, a
10 dispositive motion hearing date, a deadline for expert disclosure, and a discovery cutoff
11 date, which stipulation the Court granted (Dkt. Nos. 94-95);
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THEREFORE, Plaintiff Sonoma County Association of Retired Employees and
13 Defendant County of Sonoma hereby stipulate to the following case schedule:
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Plaintiff’s dispositive motion is due on September 5, 2014 (224 days from
15 January 24, 2014, the date Defendant filed its answer to Plaintiff’s Second Amended
16 Complaint);
17
•
Defendant’s opposition thereto and dispositive cross-motion are due on
18 October 3, 2014 (28 days after Plaintiff’s dispositive motion is filed);
19
•
Plaintiff’s reply in support of its dispositive motion and/or opposition to
20 Defendant’s dispositive cross-motion are due on October 17, 2014 (14 days after
21 Defendant’s cross-motion and opposition is filed);
22
•
Defendant’s reply in support of its dispositive cross-motion is due on
23 October 31, 2014 (14 days after Plaintiff files its opposition to Defendant’s cross-motion);
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•
The parties’ dispositive motions will be heard on November 20, 2014 at 2
25 p.m., or as soon thereafter as the Court schedules the hearing (the first civil law and
26 motion calendar after 294 days from the date Defendant filed its answer);
27
•
The deadline for expert disclosures is December 15, 2014 (323 days from
28 the date Defendant files its answer); and
6000978.1
-2STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
CV 09-4432 CW
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•
The cutoff for both expert and non-expert discovery is February 12, 2015
2 (384 days from the date Defendant filed its answer).
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4 IT IS SO STIPULATED.
5 DATED: February 28, 2014
LEWIS, FEINBERG, LEE, RENAKER &
JACKSON, P.C.
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By:
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/s/ Jeffrey Lewis
JEFFREY LEWIS
TERESA S. RENAKER
ANDREW LAH
DARIN RANAHAN
Attorneys for Plaintiff
SONOMA COUNTY ASSOCIATION OF
RETIRED EMPLOYEES
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13 DATED: February 28, 2014
HANSON BRIDGETT LLP
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By:
/s/ Raymond F. Lynch
RAYMOND F. LYNCH
LAWRENCE M. CIRELLI
STEPHEN B. PECK
JANE M. FEDDES
JULIE VEIT
Attorneys for Defendant COUNTY OF
SONOMA
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6000978.1
-3STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
CV 09-4432 CW
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ATTESTATION
I hereby attest that, for all conformed signatures indicated by a "/s/," the signatory
3 has concurred in the filing of this document.
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5 DATED: February 28, 2014
HANSON BRIDGETT LLP
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By:
/s/ Raymond F. Lynch
RAYMOND F. LYNCH
LAWRENCE M. CIRELLI
STEPHEN B. PECK
JANE M. FEDDES
JULIE VEIT
Attorneys for Plaintiff
SONOMA COUNTY ASSOCIATION OF
RETIRED EMPLOYEES
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6000978.1
-4STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
CV 09-4432 CW
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ORDER
The court, having reviewed the above Stipulation Re Case Schedule, HEREBY
3 ADOPTS THE STIPULATION AND SO ORDERS:
4
•
Plaintiff’s dispositive motion is due on September 5, 2014 (224 days from
5 January 24, 2014, the date Defendant filed its answer);
6
•
Defendant’s opposition thereto and dispositive cross-motion are due on
7 October 3, 2014 (28 days after Plaintiff’s dispositive motion is filed);
8
•
Plaintiff’s reply in support of its dispositive motion and opposition to
9 Defendant’s dispositive cross-motion are due on October 17, 2014 (14 days after
10 Defendant’s cross-motion and opposition are due on October 6, 2014);
11
•
Defendant’s reply in support of its dispositive cross-motion is due on
12 October 31, 2014 (14 days after Plaintiff files its opposition to Defendant’s cross-motion);
13
•
The Parties' dispositive motions will be heard on November 20, 2014, at 2
14 p.m., or as soon thereafter as the Court schedules the hearing (the first civil law and
15 motion calendar after 294 days from the date Defendant filed its answer;
16
•
The deadline for expert disclosures is December 15, 2014 (323 days from
17 January 24, 2014);
18
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The cutoff for both expert and non-expert discovery will be February 12,
19 2015 (384 days from January 24, 2014); and
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The discovery stay was lifted on January 24, 2014, the date Defendant filed
21 its answer to the Second Amended Complaint.
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IT IS SO ORDERED. A further case management conference will be heard on
23 November 20, 2014 along with the dispositive motions.
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25 Dated: March 3, 2014
_______
HONORABLE CLAUDIA WILKEN
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6000978.1
-5STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE
CV 09-4432 CW
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