Riggs v. Grounds et al

Filing 106

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE by Hon. Phyllis J. Hamilton granting 104 Stipulation. Joint Case Management Statement due by 5/11/2017. Initial Case Management Conference set for 5/18/2017 at 02:00 PM in Courtroom 3, 3rd Floor, Oakland. Signed by Judge Phyllis J. Hamilton on 4/10/17. (kcS, COURT STAFF) (Filed on 4/10/2017)

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1 2 3 4 CARI A. COHORN (State Bar No. 249056) COHORN LAW 101 California Street, Suite 2710 San Francisco, California 94111 Telephone: (415) 993-9005 Fax: (415) 365-9650 Email: cohorn@cohornlaw.com 5 6 7 Attorneys for Plaintiff 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT CALIFORNIA 11 OAKLAND DIVISION COHORN LAW 101 California Street, Suite 2710 San Francisco, CA 94111 Telephone: (415) 993-9005 12 13 ISAAC RIGGS, Case No: 4:13-cv-05864-PJH 14 Plaintiff, 15 16 17 v. R.T.C. GROUNDS, et. al., 18 STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER Judge: Complaint filed: Hon. Phyllis J. Hamilton December 18, 2013 Defendants. 19 20 21 22 23 This Stipulation is entered into by and between Plaintiff Isaac Riggs (“Plaintiff”) and Defendant L. Cahlander (“Defendant”), collectively, the “Parties,” by and through their 24 respective counsel. 25 WHEREAS, by Order dated March 3, 2017 (ECF No. 100), the Court appointed Cari A. 26 Cohorn to represent Plaintiff in this action; 27 28 1 STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH 1 WHEREAS, by Order dated March 7, 2017 (ECF. No. 101), the Court set a Case 2 Management Conference for April 20, 2017 and directed the parties to file a joint Case 3 Management Statement (the “Statement”) on or before April 13, 2014; 4 5 WHEREAS, promptly after her appointment, Plaintiff’s counsel initiated the process of obtaining clearance to meet with Plaintiff, an inmate at Kern Valley State Prison; 6 WHEREAS, the clearance process has been completed, but due to pre-existing schedule 7 conflicts, the earliest date on which Plaintiff’s counsel can meet with Plaintiff is April 14, 2017, 8 one day after the Parties’ joint Statement is currently due; 9 WHEREAS, counsel for both Parties’ agree that, in order to have a productive and 10 meaningful discussion before filing the Statement, Plaintiff should meet with his counsel before 11 counsel meet and confer; COHORN LAW 101 California Street, Suite 2710 San Francisco, CA 94111 Telephone: (415) 993-9005 12 WHEREAS, the Parties agree that a brief continuance of the Case Management 13 Conference and a commensurate extension of time for filing the Statement will permit more 14 efficient and effective case management, thereby conserving resources of the Parties, counsel, 15 and the Court; 16 WHEREAS, there have been no previous time modifications with respect to the Case 17 Management Conference. Previous time modifications in this case include: (1) a 60-day 18 extension of time for Defendant to file a dispositive motion (see ECF No. 27, filed 6/25/14, and 19 ECF No. 29, filed 7/8/14); (2) a 31-day extension of time for each Party to file briefs concerning 20 the effect of Plaintiff’s loss of good time credits on his sentence (see ECF No. 40, filed 12/5/14, 21 and ECF No. 41, filed 12/9/14); and (3) a 45-day extension of time for Defendant to file an 22 opposition to Plaintiff’s motion to compel discovery responses (see ECF No. 60, filed 6/2/15, 23 and ECF No. 61, filed 7/10/15); and 24 25 26 27 WHEREAS, because there are no other dates or deadlines currently on calendar in this action, the requested modification will not impact the schedule for further handling of this case. NOW, THEREFORE, pursuant to Civil Local Rules 6-2 and 7-12, the Parties hereby stipulate and agree as follows: 28 2 STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH 1 1. 2 3 4 The April 20, 2017 Case Management Conference shall be taken off calendar and rescheduled for May 4, 2017, or the earliest date thereafter convenient to the Court. 2. The deadline to file the Statement shall be continued to 7 calendar days before the date set for the Case Management Conference. 5 IT IS SO STIPULATED. 6 Dated: April 10, 2017 COHORN LAW 7 By____/s/ Cari A. Cohorn________________ 8 Cari A. Cohorn Attorneys for Plaintiff Isaac Riggs 9 10 Dated: April 10, 2017 XAVIER BECERRA ATTORNEY GENERAL OF CALIFORNIA 11 By____/s/ Kyle A. Lewis________________ 13 Kyle A. Lewis Deputy Attorney General Attorneys for Defendant L. Cahlander 14 15 16 19 R NIA NO hyl H ER FO Judge P LI RT 21 23 ED ORDER O IT IS S _________________________________ The Honorable Phyllis J. nHamilton ilto lis J. Ham 20 22 S DISTRICT TE C TA RT U O 10 Dated: April ___, 2017 A 18 PURSUANT TO STIPULATION OF THE PARTIES, IT IS SO ORDERED. Case management conference continued to May 18, 2017 at 02:00 p.m. S 17 UNIT ED COHORN LAW 101 California Street, Suite 2710 San Francisco, CA 94111 Telephone: (415) 993-9005 12 N F D IS T IC T O R C Attestation Per Local Rule 5-1(i)(3): I, Cari A. Cohorn, attest that that concurrence in the filing of this document has been 24 obtained from each of the other Signatories. 25 Dated: April 7, 2017 26 27 28 By____/s/ Cari A. Cohorn________________ Cari A. Cohorn 3 STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH

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