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1 Case No. 4:16-cv-06994-PJH

STIPULATION TO EXTEND DATES AND ORDER THEREON 

Stephen R. Jaffe (SBN 49539) 

THE JAFFE LAW FIRM 

Stephen.r.jaffe@jaffetriallaw.com 

1 Sansome Street, Suite 3500 

San Francisco, CA 94104 

Telephone: (415) 618-0100 

Attorneys for Relator 

STEVEN FALLON 

Sanjay Bhandari (SBN 181920) 

MCNAMARA SMITH LLP 

sbhandari@mcnamarallp.com 

655 W. Broadway, Suite 1680 

San Diego, CA 92101 

Telephone: (619) 269-0400 

Attorneys for Defendant 

BELL TRANSIT CORP. 

Joseph T, Urbanic (SBN302094) 

JACOBSON MARKHAM LLP 

jurbanic@jacobsonmarkham.com 

890 Cal Center Dr., Suite 210 

Sacramento, CA 95826 

Telephone: (916) 854-5969 

Attorneys for Defendants 

HAYWARD UNIFIED SCHOOL DISTRICT, 

MATTHEW WAYNE, MIRIAM GONZALEZ, 

LUCI ROGERS, and TAMMY WATSON

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

UNITED STATES OF AMERICA, ex rel., 

STEVEN FALLON, and on behalf of the 

STATE OF CALIFORNIA, 

Plaintiffs-Relators, 

v. 

BELL TRANSIT CORPORATION, et al., 

Defendants.

Case No. 4:16-cv-06994-PJH 

STIPULATION TO EXTEND DATES AND 

[PROPOSED] ORDER THEREON 

 

Pursuant to Rules 6-1(b) and 6-2 of the Northern District Civil Local Rules, Relator 

STEVEN FALLON and all active Defendants (BELL TRANSIT CORP., HAYWARD UNIFIED 

SCHOOL DISTRICT, MATTHEW WAYNE, MIRIAM GONZALEZ (formerly Delgadillo), and 

Case 4:16-cv-06994-PJH Document 86 Filed 09/14/20 Page 1 of 6
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2 Case No. 4:16-cv-06994-PJH

STIPULATION TO EXTEND DATES AND ORDER THEREON 

TAMMY WATSON) (collectively, the “Parties”) hereby agree to recommend that the Court 

extend several dates in this case for the reasons set forth below. 

1. Relator’s counsel believes he needs more time to respond to the two motions to 

dismiss filed on September 8, 2020, noting that the motions are lengthy, and that he also faces an 

opposition to a motion for summary judgment in another case, due October 8, 2020. He therefore 

requests that the briefing schedule be amended to allow his opposition to be filed one week after 

the briefing on that motion, i.e., October 15, with the reply briefing also extended one week to 

October 29. 

2. Defendants are inclined to agree as a professional courtesy. However, this briefing 

schedule conflicts with the Court’s scheduling order (ECF 51), which set the Case Management 

Conference (CMC) on October 15, 2020 at 2:00 p.m. The Parties agree that it would be best to 

continue the CMC and related dates until after the pleadings are settled. 

3. The Parties agree that these time modifications will not materially alter the 

schedule for this case since there is no trial date or other events or deadlines on calendar. 

NOW, THEREFORE, IT IS HEREBY STIPULATED BY AND AMONG THE 

PARTIES, SUBJECT TO THE COURT'S APPROVAL, THAT: 

1. Relator shall respond to Defendants’ motions to dismiss by October 15, 2020. 

2. Defendants shall file reply briefs by October 29, 2020. 

3. The CMC will occur on December 17, 2020 at 2:00 PM (or such date thereafter as 

the Court selects). The Parties will confer pursuant to Rule 26(f) at least 21 days prior, submit a 

joint CMC statement at least 7 days prior, and serve Rule 26(a)(1) initial disclosures in 

accordance with Rule 26(a)(1)(C). 

/// 

/// 

/// 

/// 

/// 

/// 

Case 4:16-cv-06994-PJH Document 86 Filed 09/14/20 Page 2 of 6
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3 Case No. 4:16-cv-06994-PJH

STIPULATION TO EXTEND DATES AND ORDER THEREON 

4. All other related case-management and Rule 26 deadlines not explicitly covered 

by this Stipulation, if any, shall also be extended and calculated based on the dates set forth 

herein. 

IT IS SO STIPULATED.

Dated: September 10, 2020 THE JAFFE LAW FIRM

By: /s/ Stephen R. Jaffe 

Stephen R. Jaffe 

Attorneys for Relator Steven Fallon 

Dated: September 10, 2020 JACOBSON MARKHAM LLP 

By: /s/ Joseph Urbanic 

Joseph Urbanic 

Attorneys for Defendants Hayward Unified 

School District, Matthew Wayne, Miriam 

Gonzalez, Luci Rogers, and Tammy Watson 

Dated: September 10, 2020 MCNAMARA SMITH LLP 

By: /s/ Sanjay Bhandari 

Sanjay Bhandari 

Attorneys for Defendant Bell Transit Corp. 

FILER’S ATTESTATION

Pursuant to Civil Local Rule 5-1(i)(3), regarding signatures, the undersigned hereby 

attests that concurrence in the filing of the document has been obtained from all of the signatories 

above. 

Dated: September 10, 2020 By: /s/ Sanjay Bhandari 

Sanjay Bhandari 

Case 4:16-cv-06994-PJH Document 86 Filed 09/14/20 Page 3 of 6
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1 Case No. 4:16-cv-06994-PJH

STIPULATION TO EXTEND DATES AND ORDER THEREON 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

UNITED STATES OF AMERICA, ex rel., 

STEVEN FALLON and on behalf of the 

STATE OF CALIFORNIA, , 

Plaintiffs-Relators, 

v. 

BELL TRANSIT CORPORATION; et al., 

Defendants. 

Case No. 4:16-cv-06994-PJH 

[PROPOSED] ORDER EXTENDING 

DATES

Pursuant to the stipulation entered by the parties and good cause appearing therefor: 

1. Relator shall respond to Defendants’ motions to dismiss on or before October 15, 

2020. 

2. Defendants shall file reply briefs on or before October 29, 2020. The Court will 

notify the Parties if the Court wishes to hear oral argument. 

3. The Case Management Conference (CMC) will occur on December 17, 2020 at 

2:00 PM. The Parties will confer pursuant to Rule 26(f) at least 21 days prior to the CMC, submit 

a joint CMC statement in the format previously ordered at least 7 days prior to the CMC, and 

serve Rule 26(a)(1) initial disclosures in accordance with Rule 26(a)(1)(C). 

Case 4:16-cv-06994-PJH Document 86 Filed 09/14/20 Page 4 of 6
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2 Case No. 4:16-cv-06994-PJH

STIPULATION TO EXTEND DATES AND ORDER THEREON 

4. All other related case management deadlines not explicitly covered by this Order, if 

any, shall also be extended and calculated based on the dates set forth herein. 

IT IS SO ORDERED. 

Dated: 

 HON. PHYLLIS J. HAMILTON 

 UNITED STATES DISTRICT JUDGE 

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 Case No. 4:16-cv-06994-PJH 

CERTIFICATE OF SERVICE 

CERTIFICATE OF SERVICE 

I hereby certify that on the 10th day of September, 2020, the foregoing document, 

STIPULATION TO EXTEND DATES AND [PROPOSED] ORDER THEREON, was 

electronically transmitted to the Clerk’s Office using the CM/ECF System for filing, and for 

transmittal of a Notice of Electronic Filing to all counsel of record who are deemed to have 

consented to electronic service via the Court’s CM/ECF system. 

 /s/ Sanjay Bhandari 

Sanjay Bhandari 

Attorneys for Defendant Bell Transit Corporation

Case 4:16-cv-06994-PJH Document 86 Filed 09/14/20 Page 6 of 6