Case: Willits v. City of Los Angeles

Goldstein, Borgen, Dardarian, & Ho

CLASS ACTION COMPLAINT against Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine.Case assigned to Judge Manuel L. Real for all further proceedings. Discovery referred to Magistrate Judge Rosalyn M. Chapman.(Filing fee $ 350 PAID.), filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (et) (mg). (Entered: 08/04/2010)

Summons Issued

21 DAY Summons Issued re Complaint - (Discovery) 1 as to Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (et)

NOTICE of Interested Parties filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (et) (mg). (Entered: 08/04/2010)

NOTICE of Related Case(s) filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Related Case(s): CV09-0287 CBM (RZx) (Rivers, Surisa) (Entered: 08/05/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant City of Los Angeles served on 8/6/2010, answer due 8/27/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Antonio Villaraigosa served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Eric Garcetti served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Paul Krekorian served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Paul Koretz served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Tom Labonge served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amante, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Ed Reyes served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Dennis P. Zine served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Herb J. Wesson, Jr served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Tony Cardenas served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Richard Alarcon served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Bernard Parks served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Janice Hahn served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Bill Rosendahl served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Jan Perry served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Jose Huizar served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

PROOF OF SERVICE Executed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, upon Defendant Greig Smith served on 8/9/2010, answer due 8/30/2010. Service of the Summons and Complaint were executed upon Julie Amanti, L.A. City Clerk in compliance with Federal Rules of Civil Procedure by personal service. Original Summons NOT returned. (Rivers, Surisa) (Entered: 08/13/2010)

ORDER re NOTICE TO COUNSEL by Judge Manuel L Real: This case has been assigned to the calendar of Judge Manuel L Real. Counsel are advised that the Court expects strict compliance with the provisions of the Local Rules and the Federal Rules of Civil Procedure. NONCOMPLIANCE MAY LEAD TO THE IMPOSITION OF SANCTIONS WHICH MAY INCLUDE THE STRIKING OF THE PLEADINGS AND ENTRY OF JUDGMENT OR DISMISSAL OF THE ACTION. (See order for further details) (shb) (Entered: 08/16/2010)

PROOF OF SERVICE filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits, Order re: Notice to Counsel served on 10/18/2010. (Rivers, Surisa) (Entered: 08/18/2010)

CERTIFICATION and NOTICE of Interested Parties filed by Defendants All Defendants, identifying MARK WILLITS, JUDY GRIFFIN, BRENT PILGREEN, COMMUNITIES ACTIVELY LIVING INDEPENDENT and FREE ("CALIF") and CITY OF LOS ANGELES, a public entity; ANTONIO VILLARAIGOSA, in his official capacity as Mayor; ERIC GARCETTI, in his official capacity as President of the Los Angeles City Council; ED REYES, PAUL KREKORIAN, DENNIS P. ZINE, TOM LABONGE, PAUL KORETZ, TONY CARDENAS, RICHARD ALARCON, BERNARD PARKS, JAN PERRY, HERB J. WESSON, JR., BILL ROSENDAHL, GREIG SMITH, JOSE HUIZAR, AND JANICE HAHN, in their official capacities as members of the Los Angeles City Council. (Hopenstand, Adena) (Entered: 08/20/2010)

FIRST STIPULATION Extending Time to Answer the complaint as to All Defendants, filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine.(Hopenstand, Adena) (Entered: 08/20/2010)

STATEMENT IN OPPOSITION TO NOTICE OF RELATED CASE filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine re: Notice of Related Case(s) 3 . (Dermer, Gabriel) (Entered: 08/24/2010)

NOTICE change of attorney info filed by defendant City of Los Angeles. and all individual defendants (Sato, Gerald) (Entered: 08/25/2010)

First NOTICE of Appearance filed by attorney Gabriel Seth Dermer on behalf of Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine (Dermer, Gabriel) (Entered: 08/25/2010)

NOTICE of Appearance filed by attorney Gerald M Sato on behalf of Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine (Sato, Gerald) (Entered: 08/25/2010)

ORDER RE TRANSFER PURSUANT TO GENERAL ORDER 08-05 -Related Case- filed. Related Case No: CV 09-00287 CBM(RZx). Case transferred from Magistrate Judge Rosalyn M. Chapman and Judge Manuel L. Real to Judge Consuelo B. Marshall and Magistrate Judge Ralph Zarefsky for all further proceedings. The case number will now reflect the initials of the transferee Judge CV 10-05782 CBM(RZx).Signed by Judge Consuelo B. Marshall (rn) (Entered: 08/25/2010)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents, RE: Notice (Other) 26 . The following error(s) was found: Incorrect event selected. Correct event to be used is Change of Attorney Information (G-06). To efile, see category: Other Filings: Notices; for event: Change of Attorney Information (G-06). If you are unsure of the events, use the SEARCH feature on CM/ECF menu bar. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lom) (Entered: 08/26/2010)

NOTICE OF MOTION AND MOTION to Certify Class Memorandum of Points and Authorities in Support Thereof filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Motion set for hearing on 10/4/2010 at 11:00 AM before Judge Consuelo B. Marshall. (Attachments: # 1 Parks Declaration, # 2 Exhibits A to G to Parks Dec, # 3 Exhibit H to Parks Dec, # 4 Willits Declaration, # 5 Pilgreen Declaration, # 6 Navarro Declaration, # 7 Griffin Declaration, # 8 Wallace Declaration, # 9 Johnson Declaration, # 10 Exhibit A to Johnson Dec, # 11 Shoup Declaration, # 12 Exhibit A and B to Shoup Dec, # 13 Exhibit C to Shoup Dec, # 14 Exhibit D and E to Shoup Dec, # 15 Mastin Declaration, # 16 Exhibit A to M to Mastin Dec, # 17 Exhibit N to Z to Mastin Dec, # 18 Dukakis Declaration, # 19 Garcia Declaration, # 20 Goldkorn Declaration, # 21 Harthorn Declaration, # 22 Jahanabad Declaration, # 23 LaPlant Declaration, # 24 Matamoros Declaration, # 25 Orlina Declaration, # 26 Overton Declaration, # 27 Ray Declaration, # 28 Rubenstein Declaration, # 29 Shimozono Declaration, # 30 Soto Declaration, # 31 Varga Declaration, # 32 Williams Declaration, # 33 Wilson Declaration, # 34 Martinez Declaration, # 35 Proposed Order Granting Class Cert Motion)(Rivers, Surisa) (Entered: 09/01/2010)

1 Parks Declaration

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2 Exhibits A to G to Parks Dec

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3 Exhibit H to Parks Dec

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4 Willits Declaration

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5 Pilgreen Declaration

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6 Navarro Declaration

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7 Griffin Declaration

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8 Wallace Declaration

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9 Johnson Declaration

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10 Exhibit A to Johnson Dec

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11 Shoup Declaration

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12 Exhibit A and B to Shoup Dec

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13 Exhibit C to Shoup Dec

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14 Exhibit D and E to Shoup Dec

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15 Mastin Declaration

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16 Exhibit A to M to Mastin Dec

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17 Exhibit N to Z to Mastin Dec

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18 Dukakis Declaration

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19 Garcia Declaration

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20 Goldkorn Declaration

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21 Harthorn Declaration

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22 Jahanabad Declaration

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23 LaPlant Declaration

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24 Matamoros Declaration

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25 Orlina Declaration

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26 Overton Declaration

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27 Ray Declaration

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28 Rubenstein Declaration

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29 Shimozono Declaration

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30 Soto Declaration

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31 Varga Declaration

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32 Williams Declaration

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33 Wilson Declaration

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34 Martinez Declaration

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35 Proposed Order Granting Class Cert Motion

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First EX PARTE APPLICATION to Continue hearing from October 4, 2010 to November 1, 2010, First EXPARTE APPLICATION for Extension of Time to File opposition filed by defendant City of Los Angeles.(Sato, Gerald) (Entered: 09/07/2010)

NOTICE OF MOTION AND MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof filed by defendant City of Los Angeles. Motion set for hearing on 11/1/2010 at 11:00 AM before Judge Consuelo B. Marshall. (Sato, Gerald) (Entered: 09/07/2010)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents, RE: First EX PARTE APPLICATION 32 ; MOTION to Stay Case pending Completion of State Court Proceeding 33 . The following error(s) was found: Proposed Document was not submitted as a separate attachment. There is no [Prop] Order attached. Please do a Notice of Lodging document and attach the [Prop] Order as the second attachment. To efile, use the SEARCH feature on the CM/ECF menu bar to find "Notice of Lodging" event. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (lom) (Entered: 09/08/2010)

Opposition Opposition re: First EX PARTE APPLICATION to Continue hearing from October 4, 2010 to November 1, 2010First EXPARTE APPLICATION for Extension of Time to File opposition 32 Declaration of Surisa E. Rivers filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Attachments: # 1 Declaration of Surisa Rivers in Support of Opposition to Def Ex Parte Application for Continuance, # 2 Exhibits to Rivers Declaration in Support of Opposition)(Rivers, Surisa) (Entered: 09/08/2010)

1 Declaration of Surisa Rivers in Support of Opposition to Def Ex Parte Applicati

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2 Exhibits to Rivers Declaration in Support of Opposition

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NOTICE OF LODGING filed re MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof 33 (Attachments: # 1 Proposed Order ORDER RE DEFENDANTS' MOTION TO STAY (COLORADO RIVER DOCTRINE))(Sato, Gerald) (Entered: 09/08/2010)

1 Proposed Order ORDER RE DEFENDANTS' MOTION TO STAY (COLORADO RIVER DOCTRINE

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NOTICE OF LODGING filed re First EX PARTE APPLICATION to Continue hearing from October 4, 2010 to November 1, 2010First EXPARTE APPLICATION for Extension of Time to File opposition 32 (Attachments: # 1 Proposed Order Defendants' Ex Parte Application to Continue Hearing etc. re Plaintiffs' Motion for Class Certification)(Sato, Gerald) (Entered: 09/08/2010)

1 Proposed Order Defendants' Ex Parte Application to Continue Hearing etc. re

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REPLY in support First EX PARTE APPLICATION to Continue hearing from October 4, 2010 to November 1, 2010First EXPARTE APPLICATION for Extension of Time to File opposition 32 filed by Defendant City of Los Angeles. (Sato, Gerald) (Entered: 09/08/2010)

STANDING ORDER by Judge Consuelo B. Marshall. This action has been assigned to the calendar of the Honorable Consuelo B. Marshall. Both the Court and the attorneys bear responsibility for the progress of litigation in the Federal Courts. To secure the just, speedy, and inexpensive determination of every action, Fed. R. Civ. P. 1, all counsel are ordered to familiarize themselves with the Federal Rules of Civil Procedure and the Local Rules of the Central District of California and comply with these rules. This Order controls the procedures used in this case. See Item 7, regarding Motions: Motions shall be filed in accordance with Local Rules 6 and 7. Local Rule 6-1 provides: "The notice of motion shall be filed with the Clerk not later than twenty-eight (28) days before the date set for hearing, and shall be served on each of the parties electronically or, if excepted from electronic filing, either by deposit in the mail or by personal service." This Court typically hears motions on Mondays, beginning at 10:00 a.m. The briefing schedule for the motion shall be governed by Local Rules 6 and 7. (Refer attached Order for other requirements.) (lom) (Entered: 09/10/2010)

MINUTES IN CHAMBERS/OFF THE RECORD by Judge Consuelo B. Marshall. The Court grants 32 Ex Parte Application of Defendants City of Los Angeles, et al. for Continuance of Hearing/Extension of Due Date for Opposition to Plaintiffs' Motion for Class Certification. The Court further orders that: 1. Defendants' opposition is due no later than October 4, 2010; 2. Plaintiffs' reply is due no later than October 18, 2010; and 3. The hearing date is scheduled for November 8, 2010 at 10:00 A.M. (lom) (Entered: 09/13/2010)

NOTICE OF MOTION AND MOTION to Dismiss Case filed by defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. Motion set for hearing on 11/15/2010 at 11:00 AM before Judge Consuelo B. Marshall. (Attachments: # 1 Memorandum of Points and Authorities in Support thereof)(Sato, Gerald) (Entered: 09/27/2010)

1 Memorandum of Points and Authorities in Support thereof

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NOTICE OF LODGING filed re MOTION to Dismiss Case 41 (Attachments: # 1 Proposed Order granting Mtn to Dismiss)(Sato, Gerald) (Entered: 09/27/2010)

1 Proposed Order granting Mtn to Dismiss

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MEMORANDUM in Opposition to MOTION to Certify Class Memorandum of Points and Authorities in Support Thereof 31 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Attachments: # 1 Proposed Order Denying Class Certification, # 2 Objections to Plaintiffs' Evidence)(Sato, Gerald) (Entered: 10/04/2010)

1 Proposed Order Denying Class Certification

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2 Objections to Plaintiffs' Evidence

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DECLARATION of Ali Nahass in opposition to MOTION to Certify Class Memorandum of Points and Authorities in Support Thereof 31 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Sato, Gerald) (Entered: 10/04/2010)

DECLARATION of Carl Mills In Opposition To MOTION to Certify Class Memorandum of Points and Authorities in Support Thereof 31 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Attachments: # 1 Continuation of Exhibit A to Mills' Declaration)(Dermer, Gabriel) (Entered: 10/04/2010)

1 Continuation of Exhibit A to Mills' Declaration

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NOTICE OF LODGING filed re MEMORANDUM in Opposition to Motion,, 43, Complaint - (Discovery), Complaint - (Discovery), Complaint - (Discovery) 1 (Attachments: # 1 Frame vs. City of Arlington (5th Cir. 8/28/2010))(Sato, Gerald) (Entered: 10/04/2010)

1 Frame vs. City of Arlington (5th Cir. 8/28/2010)

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MEMORANDUM in Opposition to MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof 33 filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Attachments: # 1 Declaration of Surisa Rivers in Support of Plaintiffs Opposition, # 2 Exhibit A to D to Rivers Declaration, # 3 Exhibit E go H to Rivers Declaration, # 4 Declaration of Rivers re Failed Filing Attempts)(Rivers, Surisa) (Entered: 10/09/2010)

1 Declaration of Surisa Rivers in Support of Plaintiffs Opposition

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2 Exhibit A to D to Rivers Declaration

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3 Exhibit E go H to Rivers Declaration

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4 Declaration of Rivers re Failed Filing Attempts

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REPLY support MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof MOTION to Stay Case pending Comletion of State Court Proceeding (Colorado River doctrine) Points and Authorities, and declaration of Gerald Sato in support thereof 33 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Sato, Gerald) (Entered: 10/18/2010)

REPLY Support MOTION to Certify Class Memorandum of Points and Authorities in Support Thereof 31 Plaintiffs' Reply to Opposition to Plaintiffs' Motion For Class Certification filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Attachments: # 1 Response to Defendants' Objections in Opposition to Plaintiffs' Motion For Class Certification)(Parks, Shawna) (Entered: 10/18/2010)

1 Response to Defendants' Objections in Opposition to Plaintiffs' Motio

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MINUTES IN CHAMBERS by Judge Consuelo B. Marshall. There are three matters currently pending before the Court: (1) Plaintiffs' Motion for Class Certification, 31 ; (2) Motion of Defendant City of Los Angeles to Stay Proceedings, 33 ; and (3) Motion of Defendant City of Los Angeles to Dismiss the Complaint pursuant to Federal Rule of Civil Procedure 12(b)(6) 41 . On the Court's own motion, a hearing on all of the above-referenced matters is hereby scheduled for Monday, November 15, 2010 at 12:00 p.m. (lom) (Entered: 10/21/2010)

MEMORANDUM in Opposition to Motion of Defendants City of Los Angeles to Dismiss the Complaint Pursuant to Federal Rule of Civil Procedure 12(b)(6) filed by Plaintiff Mark Willits. (Johnson, Mark) (Entered: 10/25/2010)

REPLY support MOTION to Dismiss Case 41 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Sato, Gerald) (Entered: 11/01/2010)

MINUTES OF Motion Hearing re: Plaintiff's Motion for Class Certification (#31); Motion of Defendant City of Los Angeles to Stay Proceedings (#33) and to Dismiss Complaint (#41) held before Judge Consuelo B. Marshall: Case called, arguments held. Motion of the City of Los Angeles to Stay proceedings 33 and Motion to Dismiss Complaint 41 are denied. Plaintiff's Motion for Class Certification is submitted without further oral arguments 31 . Court Reporter: Anne Kielwasser. (lw) (Entered: 11/16/2010)

FIRST STIPULATION Extending Time to Answer the complaint as to City of Los Angeles answer now due 12/8/2010, filed by Defendant City of Los Angeles.(Sato, Gerald) (Entered: 11/29/2010)

ANSWER to Complaint - (Discovery), Complaint - (Discovery), Complaint - (Discovery) 1 filed by defendant Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine.(Sato, Gerald) (Entered: 12/08/2010)

MINUTES (IN CHAMBERS) re Scheduling Conference by Judge Consuelo B. Marshall. On the Court's own motion, this case is set for a Scheduling Conference on Mar. 7, 2011 at 11:00 A. M. pursuant to FRCP 16(b). Counsel are reminded of their obligations to disclose information and confer on a discovery plan not later than 21 days prior to the Scheduling Conference. Counsel shall file a Rule 26(f) discovery plan within 14 days after the conference of counsel. The Rule 26(f) discovery plan shall contain the following information: 1. A brief description of the nature of the case and type of action filed and the date filed in the District Court; 2. The number of depositions to be taken by each side and the date the date the depositions are set; 3. The written discovery sought and date responses to interrogatories requests for production and requests for admissions are due; 4. The number of experts expected to be called by each side and the expert's area of expertise; 5. Proposed Pre Trial Conference date; 6. Date Demand for Jury Trial was filed; 7. Prospects of Settlement; 8. Positions of counsel re: consent to proceed before a Magistrate Judge; 9. A list of contemplated motions, including what type of motion, a tentative hearing date, and whether discovery must be conducted prior to the filing of the motions. (lom) (Entered: 12/10/2010)

ORDER by Judge Consuelo B. Marshall, that Defendants' Motion to Stay the Proceedings is DENIED 33, Defendants' Motion to Dismiss the Complaint for failure to state a claim is DENIED 41, Plaintiffs' claims asserted under state law are DISMISSED without prejudice to be pursued in state court, and the individual Defendants are DISMISSED. (lom) (Entered: 12/13/2010)

NOTICE of Unavailability of Counsel filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Rivers, Surisa) (Entered: 12/21/2010)

ORDER Granting Plaintiffs' Motion for Class Certification 31 by Judge Consuelo B. Marshall. The plaintiff class is defined as follows: All persons with mobility disabilities who have been denied access to pedestrian rights of way in the city of Los Angeles as a result of Defendants' policies and practices with regard to its pedestrian rights of way and disability access. The class is certified for injunctive and declaratory relief only. The class claims are Count I (alleging violations of the ADA) and Count II (alleging violations of the Rehabilitation Act) of Plaintiffs' Complaint. Plaintiffs Mark Willits, Judy Griffin, Brent Pilgreen, and CALIF are the class representatives. Disability Rights Legal Center and Schneider Wallace Cottrell Brayton Konecky, LLP are appointed class counsel. Pursuant to the discretion afforded the Court under Federal Rule of Civil Procedure 23(c)(2)(A) and 23(d), the Court waives notice to the class members for the purpose of class certification only. (lom) (Entered: 01/04/2011)

JOINT REPORT of The Early Meeting of Counsel Pursuant to Fed.R.Civ.P.16 and 26(f) filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Rivers, Surisa) (Entered: 02/28/2011)

MINUTES IN CHAMBERS by Judge Consuelo B. Marshall. On the Court's own motion, the Scheduling Conference which is set on Mar. 7, 2011, is hereby continued to Mar. 9, 2011 at 10:30 A.M. (lom) (Entered: 03/01/2011)

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Misc Report 60 . The following error was found: Incorrect event selected. The correct event is: Joint Report Rule 26(f) Discovery Plan. To find the correct event, see category: Other Filings: Pretrial and Trial Documents; for event: see above. If you are unsure of the events, use the SEARCH feature on the CM/ECF menu bar. In response to this notice the court may order (1) an amended or correct document to be filed (2) the document stricken or (3) take other action as the court deems appropriate. You need not take any action in response to this notice unless and until the court directs you to do so. (ir) (Entered: 03/04/2011)

NOTICE AND REQUEST of Settlement Procedure Selection (Sp3); parties request to appear before a retired judicial officer or other dispute resolution body for mediation type settlement proceedings. Filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin and Defendant City of Los Angeles. (lom) (Entered: 03/10/2011)

ORDER by Judge Consuelo B. Marshall: Granted the NOTICE AND REQUEST of Settlement Procedure Selection (Sp3) requiring the parties to appear before a retired judicial officer or other private or non-profit dispute resolution body. For Settlement Procedure No. 3, counsel are responsible for contacting the mediator at the appropriate time to arrange for further proceedings. (lom) (Entered: 03/10/2011)

MINUTES of Scheduling Conference held before Judge Consuelo B. Marshall. Court ordered as follows: 1. all fact discovery shall be completed on or before Oct. 30, 2011; 2. all expert discovery shall be completed on or before Dec. 30, 2011; 3. motions shall be set for oral argument on or before Feb. 13, 2012 at 10:00 A.M.; 4. Pre Trial Conference is set on Apr. 2, 2012 at 2:30 P.M.; 5. 10-14 day Court Trial is set on May 15, 2012 at 10:00 A.M.; and 6. Settlement Conference shall be held on or before Nov. 15, 2011.Court Reporter: Mark Schweitzer. (lom) (Entered: 03/10/2011)

ORDER from 9th CCA filed, CCA # 11-80012. The court, in its discretion, denies the petition for permission to appeal the district court's January 4, 2011 order granting class action certification. Order received in this district on 3/17/2011. (dmap) (Entered: 03/18/2011)

NOTICE OF MOTION AND MOTION to Compel Discovery From The City of Los Angeles filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Motion set for hearing on 5/30/2011 at 10:00 AM before Magistrate Judge Ralph Zarefsky. (Rivers, Surisa) (Entered: 05/03/2011)

JOINT STIPULATION to MOTION to Compel Discovery From The City of Los Angeles 67 filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Attachments: # 1 Declaration of Rivers re Joint Stipulation re Discovery Dispute, # 2 Exhibits to Rivers Declaration re Joint Stipulation, # 3 Declaration of Sato re Joint Stipulation re Discovery Dispute, # 4 Proposed Order re Joint Stipulation re Discovery Dispute)(Rivers, Surisa) (Entered: 05/03/2011)

1 Declaration of Rivers re Joint Stipulation re Discovery Dispute

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2 Exhibits to Rivers Declaration re Joint Stipulation

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3 Declaration of Sato re Joint Stipulation re Discovery Dispute

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4 Proposed Order re Joint Stipulation re Discovery Dispute

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MINUTE ORDER IN CHAMBERS by Magistrate Judge Ralph Zarefsky: On the Court's own motion, the hearing on 67 Plaintiffs' Motion to Compel Discovery, noticed for 5/30/11, is continued to 6/6/11 at 10:00AM before Magistrate Judge Ralph Zarefsky. (ib) (Entered: 05/04/2011)

NOTICE of Association of Counsel associating attorney Kimberly Colwell, Kevin Gilbert, Kimberly Drake, Britt Strottman and Eric Casher on behalf of Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. Filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine (Colwell, Kimberly) (Entered: 05/04/2011)

STIPULATION to AMEND Answer to Complaint (Discovery), Answer to Complaint (Discovery) 55 filed by Defendants Richard Alarcon, Tony Cardenas, City of Los Angeles, Eric Garcetti, Janice Hahn, Jose Huizar, Paul Koretz, Paul Krekorian, Tom Labonge, Bernard Parks, Jan Perry, Ed Reyes, Bill Rosendahl, Greig Smith, Antonio Villaraigosa, Herb J. Wesson, Jr, Dennis P. Zine. (Attachments: # 1 Proposed Order)(Colwell, Kimberly) (Entered: 05/11/2011)

1 Proposed Order

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MEMORANDUM in Support of MOTION to Compel Discovery From The City of Los Angeles 67, Supplemental filed by Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Attachments: # 1 Declaration of Rivers in Support of Supplemental Memorandum in Support of Motion to Compel Discovery)(Rivers, Surisa) (Entered: 05/16/2011)

1 Declaration of Rivers in Support of Supplemental Memorandum in Support of Motio

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NOTICE OF UNAVAILABILITY OF COUNSEL filed by Defendant City of Los Angeles. (Colwell, Kimberly) (Entered: 05/23/2011)

MINUTES OF Motion Hearing held before Magistrate Judge Ralph Zarefsky: Plaintiff's Motion to Compel Discovery 67 is denied. The motions for fees are denied. The Court's rulings are made for the reasons stated on the record. No further order shall issue. Court Recorder: Recorded on Courtsmart. (ib) (Entered: 06/13/2011)

STIPULATION AND ORDER to Allow Defendants to file an Amended Answer to Plaintiffs' Complaint by Judge Consuelo B. Marshall. The Court hereby adopts the Stipulation of the parties as an Order of this Court. Pursuant thereto, Defendants may file an Amended Answer to Plaintiffs' Complaint, Amended Answer shall be filed on or before July 1, 2011. (lom) (Entered: 06/10/2011)

AMENDED ANSWER to Complaint - (Discovery), Complaint - (Discovery), Complaint - (Discovery) 1 filed by Defendant City of Los Angeles. (Gilbert, Kevin) (Entered: 06/20/2011)

NOTICE Of Unavailability of Counsel filed by Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. (Parks, Shawna) (Entered: 06/21/2011)

NOTICE of Change of Attorney Information for attorney Surisa E Rivers counsel for Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Changing Address to 800 S. Figueroa Street, Suite 1120, Los Angeles, Ca 90017. Filed by Plaintiff Willits, et al. (Rivers, Surisa) (Entered: 07/29/2011)

NOTICE of Change of Attorney Information for attorney Paula D Pearlman counsel for Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Changing Address to 800 S. Figueroa Street, Suite 1120, Los Angeles, CA 90017. Filed by Plaintiff Willits, et al. (Pearlman, Paula) (Entered: 07/29/2011)

NOTICE of Change of Attorney Information for attorney Shawna L Parks counsel for Plaintiffs Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits. Changing address to 800 S. Figueroa Street, Suite 1120, Los Angeles CA 90017. Filed by Plaintiff Willits et al. (Parks, Shawna) (Entered: 07/29/2011)

STIPULATION to Reschedule Pre-Trial Schedule and Trial Date filed by Plaintiff Mark Willits. (Attachments: # 1 Declaration, # 2 Exhibit Exhibit A to Declaration of Mark T. Johnson, # 3 Exhibit Exhibit B to Declaration of Mark T. Johnson, # 4 Exhibit Exhibit C-P to Declaration of Mark T. Johnson, # 5 Exhibit Exhibit Q-AF to Declaration of Mark T. Johnson, # 6 Proposed Order)(Johnson, Mark) (Entered: 09/27/2011)

1 Declaration

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2 Exhibit Exhibit A to Declaration of Mark T. Johnson

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3 Exhibit Exhibit B to Declaration of Mark T. Johnson

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4 Exhibit Exhibit C-P to Declaration of Mark T. Johnson

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5 Exhibit Exhibit Q-AF to Declaration of Mark T. Johnson

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6 Proposed Order

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NOTICE of Unavailability filed by Defendant City of Los Angeles. (December 26, 2011 through January 25, 2012) (Colwell, Kimberly) (Entered: 09/28/2011)

ORDER by Judge Consuelo B. Marshall; The Court hereby adopts the Stipulation 81 of the parties. The Court modifies the pretrial schedule and continues the trial date as follows: 1. All fact discovery shall be completed on or before Apr. 30, 2012; 2. All expert discovery shall be completed on or before June 30, 2012; 3. Motions shall be set for oral argument on or before Aug. 13, 2012 at 10:00 a.m. 4. Pretrial Conference shall be set on Oct. 1, 2012 2:30 p.m.; 5. A 10-14 day Court Trial shall be set on Nov. 13, 2012 10:00 a.m. and 6. A Settlement Conference shall be held on or before May 15, 2012. (ys) (Entered: 10/03/2011)

NOTICE OF MOTION AND MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS filed by Plaintiff Mark Willits. Motion set for hearing on 1/23/2012 at 10:00 AM before Magistrate Judge Ralph Zarefsky. (Johnson, Mark) (Entered: 12/29/2011)

JOINT STIPULATION to MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS 84 filed by Plaintiff Mark Willits. (Attachments: # 1 Exhibit Declaration of Mark T. Johnson in Support of Joint Stipulation, # 2 Exhibit Exhibits A-P to Declaration of Mark T. Johnson in Support of Joint Stipulation, # 3 Exhibit Exhibits Q-FF to Declaration of Mark T. Johnson in Support of Joint Stipulation, # 4 Exhibit Exhibit Exhibit GG to Declaration of Mark T. Johnson in Support of Joint Stipulation, # 5 Exhibit Exhibits HH-LL to Declaration of Mark T. Johnson in Support of Joint Stipulation)(Johnson, Mark) (Entered: 12/29/2011)

1 Exhibit Declaration of Mark T. Johnson in Support of Joint Stipulation

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2 Exhibit Exhibits A-P to Declaration of Mark T. Johnson in Support of Joint Stipu

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3 Exhibit Exhibits Q-FF to Declaration of Mark T. Johnson in Support of Joint Stip

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4 Exhibit Exhibit Exhibit GG to Declaration of Mark T. Johnson in Support of Joint

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5 Exhibit Exhibits HH-LL to Declaration of Mark T. Johnson in Support of Joint Sti

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SUPPLEMENT to MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS 84 filed by Plaintiff Mark Willits. (Attachments: # 1 Declaration Supplemental Declaration of Mark T. Johnson in Support of Plaintiffs Motion to Compel Supplemental Responses to Requests for Production of Documents, # 2 Exhibit Exhibit A to Supplemental Declaration of Mark T. Johnson in Support of Plaintiffs Motion to Compel Supplemental Responses to Requests for Production of Documents, # 3 Exhibit Exhibit B to Supplemental Declaration of Mark T. Johnson in Support of Plaintiffs Motion to Compel Supplemental Responses to Requests for Production of Documents)(Johnson, Mark) (Entered: 01/09/2012)

1 Declaration Supplemental Declaration of Mark T. Johnson in Support of Plaintiffs

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2 Exhibit Exhibit A to Supplemental Declaration of Mark T. Johnson in Support of P

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3 Exhibit Exhibit B to Supplemental Declaration of Mark T. Johnson in Support of P

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SUPPLEMENT to MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS 84 SUPPLEMENTAL MEMORANDUM OF LAW IN SUPPORT OF OPPOSITION TO MOTION TO COMPEL SUPPLEMENTAL RESPONSES filed by Defendant City of Los Angeles. (Drake, Kimberly) (Entered: 01/09/2012)

DECLARATION of Kevin Crawford in opposition MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS 84 filed by Defendant City of Los Angeles. (Drake, Kimberly) (Entered: 01/10/2012)

OBJECTION TO UNTIMELY FILED DECLARATION OF KEVIN CRAWFORD IN OPPOSITION re: MOTION to Compel SUPPLEMENTAL RESPONSES TO REQUESTS FOR PRODUCTION OF DOCUMENTS 84 filed by Plaintiff Mark Willits. (Johnson, Mark) (Entered: 01/10/2012)

MINUTES OF Motion Hearing held before Magistrate Judge Ralph Zarefsky: Court hears argument of counsel re 84 Plaintiffs' Motion to Compel Supplemental Responses to Requests for Production of Documents, etc and Request for Attorneys' Fees. Within 10 days, each side shall provide proposed orders that will grant Plaintiff relief. Recorded on Courtsmart. (ib) (Entered: 01/26/2012)

TRANSCRIPT ORDER for date of proceedings 1/23/2012 to 1/23/2012 as to Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits Court Smart (CS). Court will contact Steve Cuellar at steve.cuellar@lls.edu with any questions regarding this order. Transcript portion requested: Other: 1/23/2012. Category: Daily. (Rivers, Surisa) (Entered: 01/26/2012)

Text Only Notice of Deficiency re Request for Transcript

NOTICE TO FILER OF DEFICIENCIES in Electronically Filed Documents RE: Transcript Order Form (AO-435) 91 . The following error(s) was found:Form AO435 must be amended to address box 17 has multiple selections, only make 1 selection. Transcript deadline terminated. You MUST electronically refile the above referenced Request for Transcript in this case to correct this deficiency. (ml) TEXT ONLY ENTRY

TRANSCRIPT ORDER for date of proceedings 1/23/2012 to 1/23/2012 as to Plaintiff Communities Actively Living Independent and Free, Judy Griffin, Brent Pilgreen, Mark Willits Court Smart (CS). Court will contact Steve Cuellar at steve.cuellar@lls.edu with any questions regarding this order. Transcript portion requested: Other: 1/23/2012. Category: Daily. (Rivers, Surisa) (Entered: 01/26/2012)

TRANSCRIPT for proceedings held on 1/23/12 9:49am. Court Reporter/Electronic Court Recorder: Exceptional Reporting Services, Inc., phone number (361)949-2988. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Electronic Court Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Notice of Intent to Redact due within 7 days of this date. Redaction Request due 2/17/2012. Redacted Transcript Deadline set for 2/27/2012. Release of Transcript Restriction set for 4/26/2012. (ml) (Entered: 01/27/2012)

NOTICE OF FILING TRANSCRIPT filed for proceedings 1/23/12 9:49am (ml) (Entered: 01/27/2012)

NOTICE OF MOTION AND MOTION to Compel 30(b)6 Testimony and Document Preservation filed by Plaintiff Mark Willits. Motion set for hearing on 2/27/2012 at 10:00 AM before Magistrate Judge Ralph Zarefsky. (Attachments: # 1 Exhibit Joint Stipulation re MTC 30(b)6 Testimony and Document Preservation)(Johnson, Mark) (Entered: 01/30/2012)

1 Exhibit Joint Stipulation re MTC 30(b)6 Testimony and Document Preservation

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DECLARATION of Mark T. Johnson In Support of MOTION to Compel 30(b)6 Testimony and Document Preservation MOTION to Compel 30(b)6 Testimony and Document Preservation 95 filed by Plaintiff Mark Willits. (Attachments: # 1 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibits A to B, # 2 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibit C, # 3 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibits D to E)(Johnson, Mark) (Entered: 01/30/2012)

1 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibits

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2 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibit

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3 Exhibit Dec of MTJ ISO MTC 30(b)6 Testimony and Document Preservation - Exhibits

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