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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CARI A. COHORN (State Bar No. 249056)
COHORN LAW
101 California Street, Suite 2710
San Francisco, California 94111
Telephone: [phone]
Fax:
[phone]
Email: [e-mail]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT CALIFORNIA

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OAKLAND DIVISION

COHORN LAW

101 California Street, Suite 2710
San Francisco, CA 94111
Telephone: [phone]

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ISAAC RIGGS,

Case No: 4:13-cv-05864-PJH

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Plaintiff,

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v.
R.T.C. GROUNDS, et. al.,

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STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER
Judge:
Complaint filed:

Hon. Phyllis J. Hamilton
December 18, 2013

Defendants.

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This Stipulation is entered into by and between Plaintiff Isaac Riggs (“Plaintiff”) and
Defendant L. Cahlander (“Defendant”), collectively, the “Parties,” by and through their

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respective counsel.
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WHEREAS, by Order dated March 3, 2017 (ECF No. 100), the Court appointed Cari A.
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Cohorn to represent Plaintiff in this action;
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STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH

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WHEREAS, by Order dated March 7, 2017 (ECF. No. 101), the Court set a Case

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Management Conference for April 20, 2017 and directed the parties to file a joint Case

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Management Statement (the “Statement”) on or before April 13, 2014;

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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;

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WHEREAS, the clearance process has been completed, but due to pre-existing schedule

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conflicts, the earliest date on which Plaintiff’s counsel can meet with Plaintiff is April 14, 2017,

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one day after the Parties’ joint Statement is currently due;

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WHEREAS, counsel for both Parties’ agree that, in order to have a productive and

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meaningful discussion before filing the Statement, Plaintiff should meet with his counsel before

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counsel meet and confer;

COHORN LAW

101 California Street, Suite 2710
San Francisco, CA 94111
Telephone: [phone]

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WHEREAS, the Parties agree that a brief continuance of the Case Management

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Conference and a commensurate extension of time for filing the Statement will permit more

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efficient and effective case management, thereby conserving resources of the Parties, counsel,

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and the Court;

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WHEREAS, there have been no previous time modifications with respect to the Case

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Management Conference. Previous time modifications in this case include: (1) a 60-day

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extension of time for Defendant to file a dispositive motion (see ECF No. 27, filed 6/25/14, and

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ECF No. 29, filed 7/8/14); (2) a 31-day extension of time for each Party to file briefs concerning

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the effect of Plaintiff’s loss of good time credits on his sentence (see ECF No. 40, filed 12/5/14,

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and ECF No. 41, filed 12/9/14); and (3) a 45-day extension of time for Defendant to file an

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opposition to Plaintiff’s motion to compel discovery responses (see ECF No. 60, filed 6/2/15,

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and ECF No. 61, filed 7/10/15); and

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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:

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STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH

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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.

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The deadline to file the Statement shall be continued to 7 calendar days before
the date set for the Case Management Conference.

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IT IS SO STIPULATED.

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Dated: April 10, 2017

COHORN LAW

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By____/s/ Cari A. Cohorn________________

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Cari A. Cohorn
Attorneys for Plaintiff Isaac Riggs

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Dated: April 10, 2017

XAVIER BECERRA
ATTORNEY GENERAL OF CALIFORNIA

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By____/s/ Kyle A. Lewis________________

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Kyle A. Lewis
Deputy Attorney General
Attorneys for Defendant L. Cahlander

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Judge P

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ED

ORDER

O
IT IS S
_________________________________
The Honorable Phyllis J. nHamilton
ilto
lis J. Ham

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S DISTRICT
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Dated: April ___, 2017

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PURSUANT TO STIPULATION OF THE PARTIES, IT IS SO ORDERED.
Case management conference continued to May 18, 2017 at 02:00 p.m.
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UNIT
ED

COHORN LAW

101 California Street, Suite 2710
San Francisco, CA 94111
Telephone: [phone]

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F
D IS T IC T O
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Attestation Per Local Rule 5-1(i)(3):
I, Cari A. Cohorn, attest that that concurrence in the filing of this document has been

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obtained from each of the other Signatories.
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Dated: April 7, 2017
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By____/s/ Cari A. Cohorn________________
Cari A. Cohorn

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STIPULATION TO CONTINUE CMC; [PROPOSED] ORDER – Case No. 4:13-CV-05864-PJH