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)

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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 9 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 18 19 UNITED STATES DISTRICT COURT 20 NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION 21 22 SONOMA COUNTY ASSOCIATION OF RETIRED EMPLOYEES, 23 Plaintiff, 24 v. 25 SONOMA COUNTY, 26 Defendant. 27 CASE NO. CV 09-4432 CW STIPULATION AND ORDER RE CASE SCHEDULE Judge: Hon. Claudia Wilken 28 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); 7 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); 12 THEREFORE, Plaintiff Sonoma County Association of Retired Employees and 13 Defendant County of Sonoma hereby stipulate to the following case schedule: 14 • 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); 24 • 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 1 • The cutoff for both expert and non-expert discovery is February 12, 2015 2 (384 days from the date Defendant filed its answer). 3 4 IT IS SO STIPULATED. 5 DATED: February 28, 2014 LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C. 6 7 By: 8 9 10 11 /s/ Jeffrey Lewis JEFFREY LEWIS TERESA S. RENAKER ANDREW LAH DARIN RANAHAN Attorneys for Plaintiff SONOMA COUNTY ASSOCIATION OF RETIRED EMPLOYEES 12 13 DATED: February 28, 2014 HANSON BRIDGETT LLP 14 15 16 17 18 19 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 20 21 22 23 24 25 26 27 28 6000978.1 -3STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE CV 09-4432 CW 1 2 ATTESTATION I hereby attest that, for all conformed signatures indicated by a "/s/," the signatory 3 has concurred in the filing of this document. 4 5 DATED: February 28, 2014 HANSON BRIDGETT LLP 6 7 8 9 10 11 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 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6000978.1 -4STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE CV 09-4432 CW 1 2 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 • The cutoff for both expert and non-expert discovery will be February 12, 19 2015 (384 days from January 24, 2014); and 20 • The discovery stay was lifted on January 24, 2014, the date Defendant filed 21 its answer to the Second Amended Complaint. 22 IT IS SO ORDERED. A further case management conference will be heard on 23 November 20, 2014 along with the dispositive motions. 24 25 Dated: March 3, 2014 _______ HONORABLE CLAUDIA WILKEN 26 27 28 6000978.1 -5STIPULATION AND [PROPOSED] ORDER RE CASE SCHEDULE CV 09-4432 CW

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