Case 2:16-cv-00885-R-JC Document 41 Filed 11/17/16 Page 1 of 4 Page ID #:220 1 2 3 4 5 6 7 8 9 V. James DeSimone (SBN: 119668) Kaveh Navab (SBN: 280235) V. JAMES DESIMONE LAW 13160 Mindanao Way, Suite 280 Marina Del Rey, California 90292 Telephone: 310.693.5561 Facsimile: 916.927.2046 John Raphling (SBN: 169554) LAW OFFICES OF JOHN RAPHLING 723 Ocean Front Walk Venice, CA 90291-3270 Attorneys for Plaintiff, SHERYN CAMPRONE, mother of deceased [Counsels for Defendants listed on following page] UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 SHERYN CAMPRONE, Plaintiff, v. CITY OF LOS ANGELES, Police Officers CLIFFORD PROCTOR, JONATHAN KAWAHARA, Police Chief CHARLIE BECK, in his individual and official capacity; and DOES 1-10, inclusive, Defendants. Case No: 2:16-cv-00885-R-JC NOTICE OF SETTLEMENT AND STIPULATION TO VACATE ALL PENDING DATES; [PROPOSED] ORDER Pre-trial Conference: Date: January 9, 2017 Time: 11:00 a.m. Crtrm: 8 Trial: February 7, 2016 Time: 9:00 a.m. Crtrm: 8 21 22 23 24 25 26 27 28 1 NOTICE OF SETTLEMENT AND STIPULATION TO VACATE ALL PENDING DATES; [PROPOSED] ORDER. Case 2:16-cv-00885-R-JC Document 41 Filed 11/17/16 Page 2 of 4 Page ID #:221 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Michael N. Feuer, Esq. Thomas H. Peters, Esq. Cory M. Brente, Esq. Colleen R. Smith, Esq. 200 North Main thStreet City Hall East, 6 Floor Los Angeles, California 90012 Telephone: (213) 978-7027 Facsimile: (213) 978-8785 Attorneys for Defendants, CITY OF LOS ANGELES and CHIEF CHARLIE BECK Thomas C. Hurrell (SBN 119876) Warren M. Williams (SBN 228742) Angela Y. Park (SBN 287315) HURREL CANTRALL LLP 300 South Grand Avenue, Suite 1300 Los Angeles, California 90071 Telephone: (213) 426-2000 Facsimile: (213) 426-2020 Attorneys for Defendant, OFFICE CLIFFORD PROCTOR Steven J. Rothans, Esq. Mark D. Rutter, Esq. Kenneth P. Korosi CARPENTER, ROTHANS & DUMONT 888 S. Figueroa St., Suite 1960 Los Angeles, California 90017 Telephone: (213) 228-0400 Facsimile: (213) 228-0401 Attorneys for Defendant, OFFICER JONATHAN KAWAHARA 19 20 21 22 23 24 25 26 27 28 2 NOTICE OF SETTLEMENT AND STIPULATION TO VACATE ALL PENDING DATES; [PROPOSED] ORDER. Case 2:16-cv-00885-R-JC Document 41 Filed 11/17/16 Page 3 of 4 Page ID #:222 1 2 3 TO THE CLERK OF THE COURT: Please take notice that the Parties have reached a settlement, pending City Council and Mayor approval, to resolve any and all claims in this lawsuit. 4 This matter was filed in this Court on February 9, 2016. A state court case on 5 behalf of Mr. Glenn’s son and the Estate of Brendon Glenn was also filed on 6 February 9, 2016. The Parties agreed to participate in mediation, which was set for 7 September 13, 2016. Due to the nature of the issues in this case, the Parties agreed 8 to defer discovery until the conclusion of the scheduled mediation. 9 On September 13, 2016 the parties agreed to a full settlement and 10 compromise of the action in the sum of $4 million dollars which will be paid with 11 a Stipulated Judgment against the City of Los Angeles only. The Parties will attend 12 a hearing on the petition to confirm the minor’s compromise in state court on 13 November 18, 2016. Due to circumstances beyond the control of either party, the 14 City Council is unable to issue a decision on this matter until early December 2016. 15 The Parties therefore respectfully request that all deadlines, including the 16 December 12, 2016 discovery deadline, and jury trial currently set for February 7, 17 2017 be taken off calendar. Attached as “Exhibit A” is a fully executed Stipulation 18 for Settlement. 19 20 Respectfully submitted, 21 22 23 24 25 26 27 Date: November 17, 2016 By: /s/ V. James DeSimone V. JAMES DESIMONE, ESQ. KAVEH NAVAB, ESQ. JOHN RALPHING, ESQ. Attorneys for Plaintiff, SHERYNE CAMPRONE, Mother of deceased 28 3 NOTICE OF SETTLEMENT AND STIPULATION TO VACATE ALL PENDING DATES; [PROPOSED] ORDER. Case 2:16-cv-00885-R-JC Document 41 Filed 11/17/16 Page 4 of 4 Page ID #:223 1 2 3 4 5 Date: November 17, 2016 By: /s/ Colleen R. Smith, Esq. (authorized via email) MICHAEL N. FEUER, ESQ. THOMAS H. PETERS, ESQ. CORY M. BRENTE, ESQ. COLLEEN R. SMITH, ESQ. Attorneys for Defendants, CITY OF LOS ANGELES CHIEF CHARLIE BECK 6 7 8 9 10 Date: November 17, 2016 By: /s/ Thomas Hurrell, Esq. (authorized via email) THOMAS C. HURRELL, ESQ. WARREN M. WILLIAMS, ESQ. ANGELA Y. PARK, ESQ. Attorneys for Defendant, OFFICE CLIFFORD PROCTOR 11 12 13 14 15 16 17 Date: November 17, 2016 By: /s/ Kenneth P. Korosi, Esq. (authorized via email) STEVEN J. ROTHANS, ESQ. MARK D. RUTTER, ESQ. JILL WILLIAMS, ESQ. KENNETH P. KOROSI, ESQ. Attorneys for Defendant OFFICER JONATHAN KAWARHARA 18 19 20 21 22 23 24 25 26 27 28 4 NOTICE OF SETTLEMENT AND STIPULATION TO VACATE ALL PENDING DATES; [PROPOSED] ORDER.