UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
October 17, 2011
MARK JOHNSON, FRANCO CALZOLAI, AND MICHAEL R. BRYANT
THE CITY AND COUNTY OF SAN FRANCISCO, THE SAN FRANCISCO FIRE DEPARTMENT,
THE SAN FRANCISCO FIRE COMMISSION, AND THE CIVIL SERVICE COMMISSION OF SAN FRANCISCO,
The opinion of the court was delivered by: United States Magistrate Judge Honorable Jacqueline Scott Corley
STIPULATION AND [PROPOSED] ORDER REGARDING SUBMISSION OF GOVERNMENT CLAIM
The City will not contest the filing of Plaintiffs' proposed government claim on the ground that it violates the March 3, 2011 protective order.
By agreeing not to contest the filing of the government claim on that ground, the Plaintiffs agree that the City has not waived any claim of protection for any document or information that has 3 been produced under the terms of the protective order based solely upon the filing of the claim. By 4 entering into this agreement the Plaintiffs waive no other arguments, contentions, or positions that it 5 has taken in any other pleadings or letters in this matter.
Dated: 10/17/11 DENNIS J. HERRERA City Attorney ELIZABETH S. SALVESON Chief Labor Attorney GINA M. ROCCANOVA Deputy City Attorney By: /s/ GINA M. ROCCANOVA Attorneys for Defendants Dated: 10/17/11 LAW OFFICES OF M.J. RANDLE By: /s/ MURLENE J. RANDLE Attorney for Plaintiffs
GOOD CAUSE HAVING BEEN FOUND, it is SO ORDERED:
I, Murlene J. Randle, attest that concurrence in the filing of this document has been obtained from Gina M. Roccanova.
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