Cochrell v. Berkeley Unified School District et al

Filing 56

STIPULATION AND ORDER to Continue Further Case Management Conference. Further Case Management Conference set for 9/28/2012 03:00 PM in Courtroom 10, 19th Floor, San Francisco. Signed by Judge Susan Illston on 08/14/2012. (tmi, COURT STAFF) (Filed on 8/14/2012)

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1 2 3 4 5 PAUL L. REIN, ESQ. CELIA MCGUINNESS, ESQ. CATHERINE M. CABALO, ESQ. LAW OFFICES OF PAUL L. REIN 200 Lakeside Drive, Suite A Oakland, CA 94612 T: 510/832-5001 F: 510/832-4787 8 BRIAN GEARINGER, ESQ. GEARINGER LAW GROUP 825 Van Ness Avenue, 4th Floor San Francisco, CA 94109-7837 T: 415/440-3102 F: 415/440-3103 9 Attorneys for Plaintiff TERRY COCHRELL 6 7 10 11 12 13 14 15 16 17 18 19 MARK J. ZEMBSCH CITY ATTORNEY’S OFFICE 2180 Milvia Street, Fourth Floor Berkeley, CA 94704 T: 510-981-6998 F: 510-981-6960 Attorney for CITY OF BERKELEY PETER P. EDRINGTON, Esq. (074355) JAMES M. MARZAN, Esq. (133931) EDRINGTON, SCHIRMER & MURPHY LLP 2300 Contra Costa Boulevard, Suite 450 Pleasant Hill, CA 94523-3936 Telephone: (925) 827-3300 Facsimile: (925) 827-3320 Attorneys for Defendant BERKELEY UNIFIED SCHOOL DISTRICT 20 UNITED STATES DISTRICT COURT 21 NORTHERN DISTRICT OF CALIFORNIA 22 23 24 25 26 27 TERRY COCHRELL, ) ) Plaintiff, ) ) vs. ) ) BERKELEY UNIFIED SCHOOL ) DISTRICT; CITY OF BERKELEY; DOES 1 ) through 10, inclusive, ) ) Defendants. ) ) CASE NO.: C11-03395 SI STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CASE MANAGEMENT CONFERENCE 28 1 STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CMC 1 Plaintiff TERRY COCHRELL and Defendants BERKELEY UNIFIED SCHOOL 2 DISTRICT and CITY OF BERKELEY, hereby jointly stipulate and request through their 3 attorneys of record that the Further Case Management Conference currently scheduled for August 4 24, 2012, be continued to September 28, 2012, to allow further settlement discussions among the 5 parties. This request is based on the following good cause: 1. The Court Ordered on June 22, 2012 that the parties return to mediation with 6 Mediator Howard Herman. 7 2. The parties have been working cooperatively in settlement discussions and have set a 8 mediation date of August 24, 2012, from 10 a.m. – 6:00 p.m. This was the only date 9 which accommodated all parties’ schedules. It is the same date as the currently 10 scheduled Further Case Management Conference. 11 3. The parties will exchange mediation statements no later than August 17, 2012, the 12 same date the Case Management Conference statement is due. 13 4. Mediation on August 24, 2012, may change the posture of the case, or may not 14 conclude before the time set for the Further Case Management Conference. Either 15 way, the case may change dramatically between filing of the Joint Case Management 16 Statement and the Conference. 5. The parties would like to proceed with the mediation process on August 24, 2012, 17 without external time constraints. 18 Therefore the parties stipulate and request that the Court set the Further Case 19 Management Conference on September 28, 2012. 20 21 IT IS SO STIPULATED. 22 // 23 // 24 // 25 // 26 // 27 // 28 2 STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CMC 1 DATED: August 9, 2012 2 LAW OFFICES OF PAUL L. REIN /s/Celia McGuinness Celia McGuinness Attorney for Plaintiff TERRY COCHRELL 3 4 5 DATED: August 13, 2012 6 GEARINGER LAW GROUP LLP /s/Brian Gearinger Brian Gearinger Attorney for Plaintiff TERRY COCHRELL 7 8 9 DATED: August 9, 2012 CITY OF BERKELEY ATTORNEY’S OFFICE 10 11 /s/Mark Zembsch Mark Zembsch Attorneys for Defendant CITY OF BERKELEY 12 13 14 DATED: August 9, 2012 EDRINGTON, SCHIRMER & MURPHY LLP 15 16 17 18 /s/James Marzan James M. Marzan Attorneys for Defendant BERKELEY UNIFIED SCHOOL DISTRICT 19 20 21 22 23 24 25 26 27 28 3 STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CMC 1 4 hereby grants the parties’ request for a continuance of the Further Case Management Conference from August 24, 2012, to September 28, 2012. 12 ER H 11 RT 10 HONORABLE SUSAN sILLSTON on san Ill t udge Su J NO 9 08/14 DATED: _____________, 2012 FO 8 R NIA 7 UNIT ED 6 S DISTRICT TE C TA RT U O S 5 LI 3 Pursuant to the stipulation, and for good cause show, IT IS SO ORDERED. The Court A 2 ORDER N F D IS T IC T O R C 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 STIPULATION AND [PROPOSED] ORDER TO CONTINUE FURTHER CMC

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