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JOSEPH P. RUSSONIELLO, CSBN 44332

United States Attorney

JOANN M. SWANSON, CSBN 88143

Assistant United States Attorney

Chief, Civil Division

ILA C. DEISS, NY SBN 3052909

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102

Telephone: (415) 436-7124

FAX: (415) 436-7169

Attorneys for the United States and

Defendants Huelga and Merendino

WILLIAM ORRICK

Deputy Assistant Attorney General

JOSHUA E.T. BRAUNSTEIN

Assistant Director

COLIN A. KISOR

Senior Litigation Counsel

Office of Immigration Litigation

District Court Section

P.O. Box 868 Ben Franklin Station

Washington D.C., 20044

Telephone: (202) 532-4331

FAX: (202) 305-7000

Attorneys for the United States

Bureau of Immigration and Customs

Enforcement

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

COMMITTEE FOR IMMIGRANT

RIGHTS OF SONOMA COUNTY, et al.,

Plaintiffs,

v.

COUNTY OF SONOMA, et al.,

Defendants.

/

No. CV-08-4220-RS

STIPULATION TO SCHEDULE A CASE

MANAGEMENT CONFERENCE;

[PROPOSED] ORDER

The parties to this action, by and through their respective counsel of record, hereby enter the

following stipulation and request entry of a conforming scheduling order. 

Stipulation and Proposed Order

Case No. CV-08-4220 RS 

*E-Filed 6/22/10*

Case 3:08-cv-04220-RS Document 197 Filed 06/22/10 Page 1 of 4
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STIPULATION

1. The previously-assigned Court had issued a Case Management and Pre-Trial Order on

December 19, 2008 (Dkt. No. 22) and thereafter vacated that order in connection with its Order

Granting in Part and Denying in Part Defendants’ Motions to Dismiss, et al., entered on July 31, 2009.

(Dkt. No. 121, at p. 42.) In its July 31, 2009 Order, the Court contemplated holding a further case

management conference at a later date. Since the date of that July 31, 2009 Order, no further case

management conference has been held, nor has the Court entered a subsequent case management or

pre-trial order.

2. However, in connection with the previously-assigned Court’s December 19, 2008

Order, the parties have scheduled a settlement conference to be held before the Honorable Magistrate

Judge Edward M. Chen on July 13, 2010.

3. On June 11, 2010, this Court entered a decision on Defendants’ motions for

reconsideration, set a date on which Answers are due (i.e., July 1, 2010), and lifted the temporary stay

of discovery; however, the Court did not set a new date for a case management conference. (Dkt No.

195.). The parties did, however, jointly submit a Case Management Statement on April 2, 2010 (Dkt

No. 176).

4. Attorneys for Federal Defendants, Office of Immigration Litigation Counsel Colin

Kisor and Lana Vahab, who are based in Washington, D.C., will attend the settlement conference

before Magistrate Chen on July 13, 2010; scheduling a case management conference for July 15, 2010,

will obviate the need for them to make a separate trip across the country to attend the conference, and

will thus conserve the resources of the United States.

5. Accordingly, counsel for the parties stipulate and jointly request the Court to schedule a

case management conference to be held on July 15, 2010, with a supplemental joint case management

statement to be filed seven days prior. 

//

//

//

Stipulation and Proposed Order

Case No. CV-08-4220 RS 2

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Respectfully submitted,

Dated: June 18, 2010 JOSEPH P. RUSSONIELLO

United States Attorney

By __________/s/_____________________

Ila C. Deiss

Assistant United States Attorney

Attorneys for Defendants United States of America and

Agent Mario Huelga and Special Agent Chris Merendino,

in their personal capacities

Dated: June 18, 2010 WILLIAM ORRICK

Deputy Assistant Attorney General, Civil Division

By________/s/_______________________

 Colin Kisor

Senior Litigation Counsel

United States Department of Justice

Office of Immigration Litigation

Attorneys for Defendant U.S. Department of Homeland

Security, Bureau of Immigration and Customs

Enforcement

Dated: June 18, 2010 Stephen M. Woodside, County Counsel

By _____________/s/__________________

Anne L. Keck, Deputy County Counsel

Sonoma County Defendants

Dated: June 18, 2010 LATHAM WATKINS, LLP

Alfred C. Pfeiffer

Melissa N. Chan

Tienlon Ho

Mary Elizabeth-Heard

Jason Daniels

Casey R. O’Connor

By___________/s/ __________________

Alfred C. Pfeiffer, Jr.

Julia Harumi Mass

Alan L. Schlosser

AMERICAN CIVIL LIBERTIES UNION

FOUNDATION OF NORTHERN

CALIFORNIA

Stipulation and Proposed Order

Case No. CV-08-4220 RS 3

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[PROPOSED] ORDER

Pursuant to stipulation, a case management conference shall be scheduled for July 15, 2010, at

10:00 a.m., with a supplemental joint case management statement due to be filed seven days prior. 

IT IS SO ORDERED. 

Date: ___________________________________

RICHARD SEEBORG

United States District Judge

Stipulation and Proposed Order

Case No. CV-08-4220 RS 4

6/21/10

Case 3:08-cv-04220-RS Document 197 Filed 06/22/10 Page 4 of 4