Pantell v. Antioch Unified School District et al

Filing 12

STIPULATION AND ORDER re 11 STIPULATION WITH PROPOSED ORDER filed by Antioch Unified School District, Adrianne Pantell. Last day to meet and confer re: initial disclosures, ADR process due by 7/15/14. Case Management Statement due by 7/29/2014. Rule 26 Meeting Report due by 7/29/2014. Case Management Conference set for 8/5/2014 01:30 PM in Courtroom 4, 3rd Floor, Oakland. Signed by Magistrate Judge Kandis A. Westmore on 6/2/14. (sisS, COURT STAFF) (Filed on 6/3/2014)

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TIMOTHY C. DAVIS (SBN 60936)
[e-mail]
THEDA VIS LAW FIRM
A Professional Corporation
625 Market Street, 12th Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendants ANTIOCH UNIFIED
SCHOOL DISTRICT, BOARD OF EDUCATION
OF ANTIOCH UNIFIED SCHOOL DISTRICT,
DR. DONALD GILL, KAI MONTGOMERY,
KAREN MATES, WENDY AGHILY, TOBINWORLD,
MIKE WILLIAMS, SARA FORGHANI,
TERESA TURNER, CHEREE MOSLEY,
ASHLEY CURTIN, and STEPHANIE BROWN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ADRIANNE PANTELL, as Guardian ad Litem of
DP, a minor,

Case No. C 14-01381 KAW

STIPULATION AND [PROPOSED] ORDER
RE: EXTENSION OF TIME FOR CERTAIN
DEFENDANTS TO RESPOND TO
COMPLAINT; AND FOR EXTENSION OF
CASE DEADLINES SPECIFIED IN ORDER
SETTING INITIAL CASE MANAGEMENT
CONFERENCE AND ADR DEADLINES

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Plaintiff,
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vs.
ANTIOCH UNIFIED SCHOOL DISTRICT;
BOARD OF EDUCATION OF ANTIOCH
UNIFIED SCHOOL DISTRICT; DR.
DONALD GILL, individually and in his official
capacity as Superintendent of Antioch Unified
School District; DAVID WAX, an individual and
in his official capacity as former Director of
Special Education for Antioch Unified School
District; KAI MONTGOMERY, an individual
and in her official capacity as former
Coordinator or Special Education; KAREN
MATES, individually and in her official
capacity as Director of Special Education for
Antioch Unified School District; WENDY
AGHILY, individually and in her official
{00045637}2740.058

(Doc. 4)

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Case No. C 14-01381 KAW

STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME FOR CERTAIN DEFENDANTS TO
RESPOND TO COMPLAINT; AND FOR EXTENSION OF CASE DEADLINES SPECIFIED IN ORDER SETTING
INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES (Doc. 4)

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capacity as Program Specialist for Contra Costa
SELPA; TOBINWORLD, a non-profit entity
doing business as a Califomia certified nonpublic
school; MIKE WILLIAMS, individually and in his
official capacity as Vice President and Behaviorist
for Tobinworld; SARA FORGHANI, individually
and in her official capacity as Principal of
Tobinworld; TERESA TURNER, individually and
in her official capacity as Teacher at Tobinworld;
CHEREE MOSLEY, individually and in her
official capacity as Teacher's Aide at Tobinworld;
ASHLEY CURTIN, individually and in her
official capacity as Teacher's Aide at Tobinworld,
STEPHANIE BROWN, individually and in her
official capacity as Teacher's Aide at Tobinworld
and DOES 1-10 inclusive,
Defendants.

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Defendants ANTIOCH UNIFIED SCHOOL DISTRICT, BOARD OF EDUCATION OF
ANTIOCH UNIFIED SCHOOL DISTRICT, DR. DONALD GILL, KAI MONTGOMERY, KAREN
MATES, WENDY AGHILY, TOBINWORLD, MIKE WILLIAMS, SARA FORGHANI, TERESA
TURNER, CHEREE MOSLEY, ASHLEY CURTIN, and STEPHANIE BROWN having been served
with process in this case in May 2014, the parties desire to pennit additional time for:
1.

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Complaint; and
2.

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The parties to engage in am informal, preliminary case discussions.

Accordingly, IT IS HEREBY STIPULATED between ANDREA M. TYTELL, counsel to

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Defendants and their counsel to conduct fact investigation prior to responding to the

Plaintiff ADRIANNE PANTELL, as Guardian ad Litem ofDP, a minor, and TIMOTHY J. DAVIS,
Counsel to Defendants ANTIOCH UNIFIED SCHOOL DISTRICT, BOARD OF EDUCATION OF
ANTIOCH UNIFIED SCHOOL DISTRICT, DR. DONALD GILL, KAI MONTGOMERY, KAREN
MATES, WENDY AGHILY, TOBINWORLD, MIKE WILLIAMS, SARA FORGHANI, TERESA
TURNER, CHEREE MOSLEY, ASHLEY CURTIN, and STEPHANIE BROWN, that:

Ill
{00045637}2740.058

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Case No. C 14-01381 KAW

STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME FOR CERTAIN DEFENDANTS TO
RESPOND TO COMPLAINT; AND FOR EXTENSION OF CASE DEADLINES SPECIFIED IN ORDER SETTING
INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES (Doc. 4)

1.

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The date for Defendants ANTIOCH UNIFIED SCHOOL DISTRICT, BOARD OF

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MONTGOMERY, KAREN MATES, WENDY AGHILY, TOBINWORLD, MIKE WILLIAMS,

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SARA FORGHANI, TERESA TURNER, CHEREE MOSLEY, ASHLEY CURTIN, and STEPHANIE

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BROWN to respond to Plaintiffs March 26, 2014 Complaint for Damages is extended to June 15,

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EDUCATION OF ANTIOCH UNIFIED SCHOOL DISTRICT, DR. DONALD GILL, KAI

2014; and

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2.

The dates specified in this Court's Order Setting Initial Case Management Conference

and ADR Deadlines, dated March 26, 2014 (Doc. 4) be extended as follows:
ORIGINAL

EXTENDED

DATE

DATE

EVENT

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June 3, 2014

Last day to:

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file ADR Certification signed by Parties and Counsel (form

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available at cand.uscomis.gov)

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file either Stipulation to ADR Process or Notice of Need for

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July 29, 2014

process selection, and discovery plan

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June 17, 2014

meet and confer re: initial disclosures, early settlement, ADR

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July 15,2014

ADR Phone Conference (form available at cand.uscourts.gov)

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Last day to file Rule 26(f) Report, complete initial disclosures or

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state objection in Rule 26(f) Report and file Case Management

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Statement per attached Standing Order re Contents of Joint Case

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Management Statement (also available at cand.uscourts.gov)

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INITIAL CASE MANAGEMENT CONFERENCE

June 24, 2014

August 5, 2014

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(CMC) in Courtroom 4, 3rd floor at 1 :30 PM

1:30 p.m.

1:30 p.m.

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Courtroom 4

Courtroom 4

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3rct Floor

rct Floor

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Ill
{00045637}2740.058

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Case No. C 14-01381 KAW

STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME FOR CERTAIN DEFENDANTS TO
RESPOND TO COMPLAINT; AND FOR EXTENSION OF CASE DEADLINES SPECIFIED IN ORDER SETTING
INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES (Doc. 4)

Dated: May 27, 2014.

Dated: May 27, 2014.

THE DAVIS LAW FIRM

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TIMOTHY C. DAVIS
Attomeys for Defendants
ANTIOCH UNIFIED SCHOOL DISTRICT,
BOARD OF EDUCATION OF ANTIOCH
UNIFIED SCHOOL DISTRICT, DR.
DONALD GILL, KAI MONTGOMERY,
KAREN MATES, WENDY AGHILY,
TOBINWORLD, MIKE WILLIAMS, SARA
FORGHANI, TERESA TURNER, CHEREE
MOSLEY, ASHLEY CURTIN, and
STEPHANIE BROWN

Andrea M. Tytell, Attot
SBN: 166835
AW OFFICES OF ANDREA M. TYTELL
2 1 Rosecrans Avenue, Suite 1350
El Segundo, Califomia 90245
Telephone: [phone]
Attorneys for Plaintiff
ADRIANNE PANTELL, AS GUARDIAN AD
LITEM OF DP, A MINOR

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[PROPOSED) ORDER

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The patiies having so stipulated, and good cause appearing therefor,

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IT IS HEREBY ORDERED that:

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The date for Defendants ANTIOCH UNIFIED SCHOOL DISTRICT, BOARD OF

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EDUCATION OF ANTIOCH UNIFIED SCHOOL DISTRICT, DR. DONALD GILL, KAI

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MONTGOMERY, KAREN MATES, WENDY AGHILY, TOBINWORLD, MIKE WILLIAMS,

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SARA FORGHANI, TERESA TURNER, CHEREE MOSLEY, ASHLEY CURTIN, and STEPHANIE

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BROWN to respond to Plaintiff's March 26, 2014 Complaint for Damages is extended to June 15,

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2014;and

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The dates specified in this Court's Order Setting Initial Case Management Conference

and ADR Deadlines, dated March 26, 2014 (Doc. 4) aree extended as follows:

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ORIGINAL

EXTENDED

DATE

DATE

EVENT

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June 3, 2014

Last day to:

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meet and confer re: initial disclosures, early settlement, ADR

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July 15, 2014

process selection, and discovery plan

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{00045637)2740.058

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Case No. C 14-013 81 KAW

STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME FOR CERTAIN DEFENDANTS TO
RESPOND TO COMPLAINT; AND FOR EXTENSION OF CASE DEADLINES SPECIFIED IN ORDER SETTING
INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES (Doc. 4)

file ADR Certification signed by Parties and Counsel (fonn
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available at cand.uscourts.gov)

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file either Stipulation to ADR Process or Notice ofNeed for

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ADR Phone Conference (form available at cand.uscowis.gov)

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state objection in Rule 26(£) Report and file Case Management

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Statement per attached Standing Order re Contents of Joint Case

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Management Statement (also available at cand:uscourts.gov)

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July 29, 2014

INITIAL CASE MANAGEMENT CONFERENCE (CMC)

June 24, 2014

August 5, 2014

in Courtroom 4, 3rd floor at 1:30PM

1:30 p.ni.

1:30 p.m.

Comiroom 4

Courtroom 4

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June 17, 2014

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Last day to file Rule 26(£) Report, complete initial disclosures or

3rd Floor

3rd Floor

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IT IS SO ORDERED.

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Date:

6/2/14

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Hon. Kandis A. Westmore
UNITED STATES MAGISTRATE JUDGE

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{00045637)2740.058

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Case No. C 14-013 81 KAW

STIPULATION AND [PROPOSED] ORDER RE: EXTENSION OF TIME FOR CERTAIN DEFENDANTS TO
RESPOND TO COMPLAINT; AND FOR EXTENSION OF CASE DEADLINES SPECIFIED IN ORDER SETTING
INITIAL CASE MANAGEMENT CONFERENCE AND ADR DEADLINES (Doc. 4)