BAY AREA LEGAL AID LISA GREIF, State Bar No. 214537 NAOMI YOUNG, State Bar No. 105041 ROBERT P. CAPISTRANO, State Bar No. 70382 1735 Telegraph Avenue Oakland, California 94612 Telephone: 510-663-4744 Facsimile: 510-663-4740 Email: firstname.lastname@example.org email@example.com firstname.lastname@example.org NATIONAL HOUSING LAW PROJECT JAMES R. GROW, State Bar No. 83548 KENT QIAN, State Bar No. 264944 703 Market St. Suite 2000 San Francisco, CA 94103 Telephone: 415-546-7000 Facsimile: 415-546-7007 Email: email@example.com firstname.lastname@example.org Attorneys for Plaintiffs PARK VILLAGE APARTMENTS TENANTS ASSOCIATION, FOSTER, et al.
JOINT REQUEST TO CONTINUE SETTLEMENT CONFERENCE AND [PROPOSED] ORDER
Plaintiffs, PARK VILLAGE APARTMENT TENANTS ASSOCIATION, et al. (Plaintiffs) 2 and Defendants, MORTIMER HOWARD TRUST and MORTIMER HOWARD (Defendants), in 3 the above-entitled action, by and through respective counsel, hereby request that the settlement 4 conference with Magistrate Judge Beeler, be continued to a date to be determined by the Court's 5 availability. In an effort to assist the Court and allow sufficient time to come to a final resolution 6 on the remaining issues in the case, the parties would prefer to have the settlement conference reset 7 to a date in August 2012, if possible. 8
The reasons for this continuance request include: 9 10
1. The parties are currently engaged in settlement discussions and significant progress has been made toward a final stipulated agreement to make the preliminary injunction upheld by the Ninth Circuit on February 24, 2011 permanent.
2. This agreement will be a resolution of all issues and will include a dismissal of the 14 case. 15
3. The parties agree that only a few negotiation points remain and feel it would be more 16 productive at this time to continue settlement negotiations between themselves with the goal of a 17 final resolution.
Having reviewed the Judge Beeler's calendar for available dates, the parties agree that the 19 following dates are acceptable to them: 20 21
Monday, August 6, 2012 22
Tuesday, August 7, 2012 23
Thursday August 9, 2012 24
Additionally, Defendants also request that the deadline for filing the answer also be 25 extended to the day before the reset settlement conference date. 26 27
I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature ...