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17-cv-00600-LB

PLAINTIFF’S AND DEFENDANTS’ STIPULATIONS OF FACT

MIRIAM KIM (State Bar No. 238230)

miriam.kim@mto.com

EMILY C. CURRAN-HUBERTY (State Bar No. 293065)

emily.curran-huberty@mto.com

SKYLAR D. BROOKS (State Bar No. 310707)

skylar.brooks@mto.com

MUNGER, TOLLES & OLSON LLP

560 Mission Street

Twenty-Seventh Floor

San Francisco, California 94105-2907

Telephone: (415) 512-4000

Facsimile: (415) 512-4077

Attorneys for Plaintiff

RENEE LEPAGE

DALE L. ALLEN, JR., State Bar No. 145279

dallen@aghwlaw.com

PHILIP J. DOWNS, JR., State Bar No. 302939

pdowns@aghwlaw.com

ALLEN, GLAESSNER, HAZELWOOD & WERTH, LLP

180 Montgomery Street, Suite 1200

San Francisco, CA 94104

Telephone: (415) 697-2000

Facsimile: (415) 813-2045

Attorneys for Defendants

COUNTY OF NAPA, COUNTY OF NAPA SHERIFF’S 

DEPARTMENT, DEPUTY TIMOTHY REID

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

RENEE LEPAGE, an individual,

Plaintiff,

vs.

COUNTY OF NAPA; COUNTY OF NAPA 

SHERIFF’S DEPARTMENT; AND DEPUTY 

TIMOTHY REID,

Defendants.

Case No. 3:17-cv-00600-LB

PLAINTIFF’S AND DEFENDANTS’ 

STIPULATIONS OF FACT

Case 3:17-cv-00600-LB Document 145 Filed 10/10/19 Page 1 of 3
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-1- 17-cv-00600-LB

PLAINTIFF’S AND DEFENDANTS’ STIPULATIONS OF FACT

PLAINTIFF’S AND DEFENDANTS’ STIPULATIONS OF FACT

Plaintiff Renee LePage and Defendants County of Napa, County of Napa Sheriff’s 

Department, and Deputy Timothy Reid, by and through their attorneys, stipulate as follows:

1. County of Napa is and, at all relevant times was, a public entity, duly organized and 

existing under and by virtue of the laws of the State of California.

2. Defendant County of Napa Sheriff’s Department is a subdivision of Defendant 

County of Napa, which employs, manages, and supervises deputy sheriffs, who are 

law enforcement officers.

3. Deputy Reid has been employed as a deputy sheriff with the County of Napa and 

the Napa County Sheriff’s Department since August 31, 2015.

4. Deputy Reid was acting under color of state law at all times relevant to this action.

5. Deputy Reid was acting within the course and scope of his employment at all times 

relevant to this action.

6. On the morning of December 1, 2015, Ms. LePage was lawfully and peacefully in 

Department E of the Napa County Superior Courthouse located at 1111 Third 

Street, Napa, California (“Courthouse”) for an unrelated case.

7. As Ms. LePage was exiting Courtroom E, she encountered Deputy Reid in the 

vestibule area between the courtroom and the public hallway.

8. The entrance to Courtroom E from the public hallway consists of one set of double 

doors that lead to a vestibule, followed by another set of double doors that lead to 

the courtroom.

9. There is an attorney conference room off of each side of the vestibule. Each 

conference room is accessed through a solid door.

10. At the time Deputy Reid encountered Ms. LePage, he was wearing his Departmentissued bulletproof vest.

Case 3:17-cv-00600-LB Document 145 Filed 10/10/19 Page 2 of 3
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-2- 17-cv-00600-LB

PLAINTIFF’S AND DEFENDANTS’ STIPULATIONS OF FACT

DATED: October 10, 2019 For Plaintiff

MUNGER, TOLLES & OLSON LLP

MIRIAM KIM

EMILY C. CURRAN-HUBERTY

SKYLAR D. BROOKS

By: /s/ Emily Curran-Huberty

 

 Attorneys for Plaintiff RENEE LEPAGE

DATED: October 10, 2019 For Defendants

ALLEN, GLAESSNER,

HAZELWOOD & WERTH, LLP

DALE L. ALLEN, JR.

PHILIP J. DOWNS, JR.

By: /s/ Dale L. Allen, Jr.

 

Attorneys for Defendants COUNTY OF NAPA, 

COUNTY OF NAPA SHERIFF’S DEPARTMENT, 

DEPUTY TIMOTHY REID

ATTESTATION

Under Local Civil Rule 5-1(i), I hereby attest that all other signatories listed, and on whose 

behalf this filing is submitted, concur in the filing’s content and have authorized the filing.

Dated: October 10, 2019 /s/ Emily Curran-Huberty

Case 3:17-cv-00600-LB Document 145 Filed 10/10/19 Page 3 of 3