Raman v. City and County of San Francisco et al

Filing 101

STIPULATION AND ORDER CONTINUING CASE MANAGEMENT CONFERENCE re 98 Stipulation filed by Barry Young, Dennis Doyle, John Radogno, Charles Lewis, Allen Nance, City and County of San Francisco, Alfred Fleck, Wayne Williams, Timothy Diestel. Signed by Judge Phyllis J. Hamilton on 11/4/09. (nah, COURT STAFF) (Filed on 11/4/2009)

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DENNIS J. HERRERA, State Bar #139669 City Attorney ELIZABETH S. SALVESON, State Bar #83788 Chief Labor Attorney LAUREN M. MONSON, State Bar #242819 Deputy City Attorney Fox Plaza 1390 Market Street, Fifth Floor San Francisco, California 94102-5408 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail] Attorney for Defendants CITY AND COUNTY OF SAN FRANCISCO, TIMOTHY DIESTEL, DENNIS DOYLE, ALFRED FLECK, CHARLES LEWIS, ALLEN NANCE, JOHN RADOGNO, WAYNE WILLIAMS, and BARRY YOUNG

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ALFRED LAM, SHANIA RAMAN, FRANK CHEN, PAULA LEIATO, and GREGORY CHIN, Plaintiff(s), vs. THE CITY AND COUNTY OF SAN FRANCISCO, a municipality and political subdivision of the State of California, JUVENILE PROBATION DEPARTMENT, TIMOTHY DIESTEL, DENNIS DOYLE, ALFRED FLECK, CHARLES LEWIS, ALLEN NANCE, JOHN RADOGNO, BRYAN THOMASSON, WAYNE WILLIAMS, BARRY YOUNG, and JOHN DOES 1-10 in their individual and professional capacities, Case No. C 08-4702 PJH STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE Courtroom: Oakland, 3rd floor, Room 3 Judge: Hon. Phyllis J. Hamilton Action Filed: Trial Date: October 6, 2008 None set

IT IS STIPULATED BY THE PARTIES AS FOLLOWS: 1) 2) A further Case Management Conference is currently set for November 5, 2009. There is good cause to continue the Case Management Conference one week, to the

date of November 12 because : (a) The City's counsel in this matter, Lauren Monson, is currently in
DEF. STIP TO CONT. CMC CASE NO. C 08-4702 PJH

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the middle of a three day grievance arbitration. The arbitration was originally set for one day, October 20, 2009. At the end of the first day of hearing, the Arbitrator subsequently set two additional days for arbitration, November 5 and November 6. At the time the additional dates were set, Ms. Monson did not realize it conflicted with the November 5 case management conference. Ms. Monson has attempted to continue the arbitration without response from opposing counsel; (b) Due to the complex nature of this case, Ms. Monson does not feel it is appropriate to have another attorney appear for her at the Case Management Conference on November 5; and (c) There are two pending motions to dismiss, motions to sever and motions for a more definitive statement filed by Defendants in this action. One motion filed by defendants the City, Timothy Diestel, Dennis Doyle, Alfred Fleck, Charles Lewis, Allen Nance, John Radogno, Wayne Williams and Barry Young, and the second filed by defendant Bryan Thomasson. Defendants believe the outcome of these motions may significantly impact the scheduling and planning of this case and thus it may be more useful to have a ruling on these motions before the next CMC conference. 3) The parties stipulate to a one week continuance of the Case Management Conference,

to the date of November 12 at 2:30 p.m., and request that the Court enter an order consistent with this stipulation. Dated: 10/30/09 By: /s/ Lauren M. Monson LAUREN M. MONSON Attorneys for Defendants CITY AND COUNTY OF SAN FRANCISCO, TIMOTHY DIESTEL, DENNIS DOYLE, ALFRED FLECK, CHARLES LEWIS, ALLEN NANCE, JOHN RADOGNO, WAYNE WILLIAMS, AND BARRY YOUNG

Dated: 10/30/09 By: /s/ Geoffrey Gordon-Creed GEOFFREY GORDON-CREED Attorney for Defendant, BRYAN THOMASSON Dated: 10/30/09 By: /s/ Evgenii Sverdlov EVGENII SVERDLOV Attorney for Plaintiffs 2
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DEF. STIP TO CONT. CMC CASE NO. C 08-4702 PJH

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PURSUANT TO STIPULATION, IT IS SO ORDERED: The further Case Management Conference set for November 5 is continued one week to the January 7, 2010 at 2:00 p.m. date of November 12, 2009 at 2:30 P.M.
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Dated: 11/4/09

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