The opinion of the court was delivered by: The Honorable Maxine M. Chesney United States District Judge
MURLENE J. RANDLE, State Bar #98124 LAW OFFICES OF M. J.
235 Montgomery Street, Suite 716 San Francisco, CA 94104
Telephone: (415) 352-0189 Facsimile: (415) 352-0187
Attorney for the Plaintiffs
DENNIS J. HERRERA, State Bar #139669
ELIZABETH S SALVESON, State Bar #83788
Chief Labor Attorney
JONATHAN ROLNICK, State Bar #151814
Deputy City Attorney
Fox Plaza 1390 Market Street, Fifth Floor
San Francisco, California 94102-5408 Telephone: (415) 554-3815
Facsimile: (415) 554-4248 E-Mail: firstname.lastname@example.org
Attorneys for the Defendants
STIPULATION IN SUPPORT OF THE PARTIES' JOINT ADMINISTRATIVE MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE AND
THE CITY AND COUNTY OF SAN PROPOSED ORDER 23
1. On March 2, 2012, the parties appeared before the court at the initial Case Management Conference.
their complaint to add new claims and parties upon the receipt of Right to Sue Notices that had been 5 requested from the Department of Justice. The court, finding it premature to schedule future dates due 6 to the proposed amendment, ordered that the Case Management Conference be continued to May 4, 2012 at 10:30 a.m. for a further Case Management Conference so that the parties could report on their progress, if any.
10 claims they wish to add on April 5, 2012, April 16, 2012, and April 26, 2012. The plaintiffs now have 11 all the Right to Sue Notices required to amend their complaint.
4. On April 27, 2012, via telephone, the parties discussed the upcoming Case
Management Conference and proposed amended complaint. The parties agreed to stipulate to a 30-14 day continuance of the Case Management Conference set for May 4, 2012 so that: the plaintiffs' can 15 draft a proposed amended complaint; the parties can meet and confer over the possibility of a 16 stipulation to file said amended complaint; and the plaintiffs can take whatever steps necessary based 17 on the results of their conference. If the court grants this continuance, the parties will then report their 18 progress to the court at the continued Case Management Conference. 19
20 for a continuance and the hereby stipulate to continue the May 4, 2012 Case Management Conference 21 to Friday, June 1, 2012 at 10:30 a.m., or another date and time that is convenient for the court.
Dated: April 30, 2012 LAW OFFICES OF MURLENE J. RANDLE 24 Murlene J. Randle, Attorney for the Plaintiffs 2. Among other issued discussed, plaintiffs informed the court that they planned to amend 3. Plaintiffs received Right to Sue Notices for the additional parties they wish to join and 5. Accordingly, the parties believe that the above-stipulated facts constitute good cause By: /S/ 25 Dated: April 30, 2012 DENNIS J. HERRERA, City Attorney 27 Jonathan Rolnick, Deputy City Attorney Attorneys for the City and County of San Francisco I, Murlene J. Randle, attest that concurrence in the filing of this document has been obtained from Jonathan Rolnick, Deputy City Attorney.
PURSUANT TO STIPULATION, GOOD CAUSE HAVING BEEN FOUND, the Court hereby grants 8 the parties Joint Motion For Administrative Relief to Continue the Case Management Conference to: 9
June 1 , 2012. A Joint Case Management Statement ...