Opinion
Case No. CV 09 5503 JSW (JSC)
10-17-2011
MARK JOHNSON, FRANCO CALZOLAI, and MICHAEL R. BRYANT Plaintiffs, v. THE CITY AND COUNTY OF SAN FRANCISCO, THE SAN FRANCISCO FIRE DEPARTMENT, THE SAN FRANCISCO FIRE COMMISSION, and THE CIVIL SERVICE COMMISSION OF SAN FRANCISCO, Defendants.
DENNIS J. HERRERA City Attorney ELIZABETH S. SALVESON Chief Labor Attorney GINA M. ROCCANOVA Deputy City Attorney GINA M. ROCCANOVA Attorneys for Defendants LAW OFFICES OF M.J. RANDLE MURLENE J. RANDLE Attorney for Plaintiffs
MURLENE J. RANDLE, State Bar #98124
LAW OFFICES OF M. J. RANDLE
Attorney for the Plaintiffs DENNIS J. HERRERA, State Bar #139669
City Attorney
ELIZABETH S SALVESON, State Bar #83788
Chief Labor Attorney
GINA M. ROCCANOVA, State Bar #201594
Deputy City Attorney
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO
STIPULATION AND [PROPOSED] ORDER REGARDING SUBMISSION OF GOVERNMENT CLAIM
The City will not contest the filing of Plaintiffs' proposed government claim on the ground that it violates the March 3, 2011 protective order.
By agreeing not to contest the filing of the government claim on that ground, the Plaintiffs agree that the City has not waived any claim of protection for any document or information that has been produced under the terms of the protective order based solely upon the filing of the claim. By entering into this agreement the Plaintiffs waive no other arguments, contentions, or positions that it has taken in any other pleadings or letters in this matter.
DENNIS J. HERRERA
City Attorney
ELIZABETH S. SALVESON
Chief Labor Attorney
GINA M. ROCCANOVA
Deputy City Attorney
GINA M. ROCCANOVA
Attorneys for Defendants
LAW OFFICES OF M.J. RANDLE
MURLENE J. RANDLE
Attorney for Plaintiffs
GOOD CAUSE HAVING BEEN FOUND, it is SO ORDERED:
HONORABLE JACQUELINE SCOTT CORLEY
United States Magistrate Judge
I, Murlene J. Randle, attest that concurrence in the filing of this document has been obtained from Gina M. Roccanova.