STIPULATION AND [PROPOSED] ORDER AFTER REASSIGNMENT SCHEDULING INITIAL CASE MANAGEMENT CONFERENCE FOR MAY 1, 2015

SAMUEL CONTI, District Judge.

STIPULATED REQUEST FOR SCHEDULING ORDER

On March 10, the Court issued an order (Doc. 12) finding this case related to the lower-numbered action D'Paris Williams v. City of San Francisco, et al., Case No. 14-cv-05612-SC, reassigning the case to the Honorable Samuel Conti, and vacating the existing initial case management conference date. A new date has not yet been set. Therefore, the parties stipulate to a request for an order scheduling the initial case management conference date for May 1, 2015, at 10:00 a.m.

The parties are concurrently filing a stipulated request for an order continuing the initial case management conference in the lower-number related case, Williams, from Friday April 3, 2015 at 10:00 a.m. to Friday May 1, 2015 at 10:00 a.m., the same date.

The parties accordingly respectfully request that the initial case management conferences in both related cases be set for May 1, 2015 at 10:00 a.m., and the above stipulation be entered as the Court's Order.

IT IS SO STIPULATED.

DECLARATION IN SUPPORT OF STIPULATED REQUEST FOR SCHEDULING ORDER

I, Peter J. Keith declare as follows:

1. I am a Deputy City Attorney in the Office of the San Francisco City Attorney, counsel of record to Defendants City and County of San Francisco, Theodore Polovina, Joseph Emanuel, and Jose Calvo-Perez. I am also counsel of record to the defendants in the action D'Paris Williams v. City of San Francisco, et al., Case No. 14-cv-05612-SC, a lower-numbered action which this Court found related (Doc. 12). The parties are concurrently filing a stipulated request to continue the case management conference in that case to May 1, 2015.) I have personal knowledge of the contents of this declaration, except where indicated otherwise, and I could and would testify competently thereto if called upon to do so.

2. Good cause. The parties request that the case management conference be set for May 1, 2015 in order to afford counsel enough time to fulfill their responsibilities to gather materials necessary to make full and complete initial disclosures, to formulate a discovery plan, and to reach agreement regarding case deadlines. I am facing time constraints because while I am lead counsel for defendants in this case, I am also counsel of record in City and County of San Francisco et al. v. Teresa Sheehan, U.S. Supreme Court Case No. 13-1412, which is set for oral argument in the United States Supreme Court on March 23, 2015. Because of commitments arising from that Supreme Court case which cannot be posponed, I do not have the necessary time to devote to this case under the current case management deadlines to gather materials necessary to make full and complete initial disclosures, or to formulate a discovery plan and reach agreement regarding case deadlines. In addition, I have a medical procedure which had to be postponed for several months until after the March 23, 2015 Supreme Court argument, and I will be undergoing that procedure and recovering from it through mid-April 2015.

3. Previous time modifications. By stipulation the parties extended the time to file an Answer from February 25 to March 18. There have been no other time modifications.

4. Effect of the proposed schedule on the schedule for the case. The requested schedule is not expected to affect any other deadlines or the parties' requested trial dates.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed March 12, 2015 at San Francisco, California.

[PROPOSED] ORDER

PURSUANT TO STIPULATION AND GOOD CAUSE SHOWN, the Court hereby orders that the Case Management Conference in the above entitled action is sccheduled for May 1, 2015, at 10:00 a.m.

IT IS SO ORDERED.