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Black Parallel School Board v. Sacramento City Unified School District

United States District Court, E.D. California

December 20, 2019

BLACK PARALLEL SCHOOL BOARD et al., Plaintiffs,
v.
SACRAMENTO CITY UNIFIED SCHOOL DISTRICT et al., Defendants.

          LOZANO SMITH, SLOAN R. SIMMONS ALYSSA R. BIVINS Attorneys for Defendants SACRAMENTO CITY UNIFIED SCHOOL DISTRICT, JORGE A. AGUILAR, CHRISTINE A. BAETA, JESSIE RYAN, DARREL WOO, MICHAEL MINNICK, LISA MURAWSKI, LETICIA GARCIA, CHRISTINA PRITCHETT, MAI VANG, and BOARD OF EDUCATION OF SACRAMENTO CITY UNIFIED SCHOOL DISTRICT

          EQUAL JUSTICE SOCIETY DISABILITY RIGHTS CALIFORNIA NATIONAL CENTER FOR YOUTH LAW WESTERN CENTER ON LAW AND POVERTY MONA TAWATAO Attorney for Plaintiffs BLACK PARALLEL SCHOOL BOARD, S.A., by and through his Next Friend, AMY A., K.E., by and through his Next Friend, JENNIFER E., and C.S., by and through his General Guardian, SAMUEL S.

          LIST OF ADDITIONAL ATTORNEYS: EVA PATERSON (SBN: 67081) MONA TAWATAO (SBN: 128779) Equal Justice Society Attorneys for Plaintiffs

          CARLY J. MUNSON (SBN: 254598) BRIDGET CLAYCOMB (SBN: 312001) LAUREN LYSTRUP (SBN: 326849) ANTIONETTE DOZIER (SBN: 244437) RICHARD ROTHSCHILD (SBN: 67356) Western Center on Law and Poverty

          NOTICE OF JOINT MOTION AND JOINT MOTION FOR STAY OF LITIGATION PENDING AGREED-UPON STRUCTURED SETTLEMENT NEGOTIATIONS; AND ORDER

          Troy L. Nunley, United States District Judge

         TO THE HONORABLE COURT:

         PLEASE TAKE NOTICE THAT Plaintiffs Black Parallel School Board, S.A., K.E., and C.S. (“Plaintiffs”), and Defendants Sacramento City Unified School District, et al., and all of them (the “District”) (collectively herein, “Parties”), through their respective counsel of record, hereby jointly move this Court for a stay of this litigation for seven months so that the parties may engage in agreed-upon structured settlement negotiations, as set forth below.

         As the Parties jointly move for the requested stay and agree on the propriety and scope of same, the Parties do not believe argument or appearance is necessary for the Court to consider the requested stay, but are prepared to appear if the Court so orders.

         STATEMENT OF FACTS

         The Parties hereby stipulate to the following facts:

         Plaintiffs filed their Complaint and initiated the instant action on September 5, 2019 (ECF No. 1).

         Plaintiffs served the District with its Complaint on September 10, 2019, and filed the related Proof of Service on October 17, 2019 (ECF No. 7).

         Shortly after Plaintiffs' service of the Complaint, the Parties engaged in communications to negotiate a stay of this litigation for a designated period of time to allow the Parties to participate in good faith negotiations toward a potential global resolution of this action, thereby preserving the Parties' and the Court's time and resources.

         On September 24, 2019, as the Parties' communications described in paragraph 3 continued to make progress and were ongoing, the Parties stipulated to and the Court granted an extension of time for the District to ...


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