City and County of San Francisco v. City of Oakland

STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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[Full Counsel Listing on Signature Page]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CITY AND COUNTY OF SAN FRANCISCO,
Plaintiff,
v.
CITY OF OAKLAND AND PORT OF
OAKLAND,
Defendants.
Case No. 3:24-cv-02311-TSH
STIPULATION TO CONTINUE
FEBRUARY 26, 2026 HEARING ON
MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT
[DKT. 120]
CITY OF OAKLAND, A MUNICIPAL
CORPORATION, ACTING BY AND
THROUGH ITS BOARD OF PORT
COMMISSIONERS (PORT OF OAKLAND),
Counterclaimant,
v.
CITY AND COUNTY OF SAN FRANCISCO,
Counterclaim Defendant.
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 1 of 6

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STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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STIPULATION
Plaintiff and Counterclaim-Defendant City and County of San Francisco (the “City”), and
Defendant and Counterclaimant the City of Oakland, a municipal corporation, acting by and
through its Board of Port Commissioners (the “Port”) (together, the “Parties” and each, a
“Party”), by and through their undersigned attorneys, hereby stipulate and agree pursuant to Civil
Local Rules 7-12 as follows:
 	WHEREAS, on November 12, 2025, the City filed a Motion for Leave to File
Second Amended Complaint (Dkt. 120) (“Motion”);
 	WHEREAS, on December 4, 2025, the Parties filed a Stipulation Regarding
Amendment of Case Management Deadlines (Dkt. 127) (“Stipulation to Extend Deadlines”),
which sought to extend the case schedule by roughly three months;
 	WHEREAS, the Court granted the Stipulation to Extend Deadlines with slight
modifications on December 4, 2025 (Dkt. 128);
 	WHEREAS, on December 16, 2025, the Parties participated in an over twelve-
hour mediation before a JAMS mediator, which resulted in a non-binding term sheet that the
parties have been attempting to reduce to a final settlement agreement;
 	WHEREAS, on December 17, 2025, the Court entered an Order, pursuant to the
Parties’ Stipulation to Continue Hearing on Motion for Leave to File Second Amended Complaint
[Dkt. 120], which continued the hearing on Plaintiff’s Motion to January 22, 2026 at 10:00 a.m.
(Dkt. 131);
 	WHEREAS, on January 21, 2026, the Court executed an Order, pursuant to the
Parties’ Stipulation to Continue Hearing on Motion for Leave to File Second Amended Complaint
[Dkt. 120], which continued the hearing on Plaintiff’s Motion to February 26, 2026 at 10:00 a.m.
(Dkt. 133);
 	WHEREAS the Parties are working diligently with the mediator to attempt to
reach a final agreement, including the respective approvals needed but require additional time;
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 2 of 6

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STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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 	WHEREAS, the Parties intend later this week to file a case scheduling stipulation,
but given the imminency of the February 26th hearing deadline, request that the Court move the
hearing by three weeks or the next available hearing date thereafter;
 	WHEREAS, to avoid potentially unnecessary expenditures and events that may
interfere with the resolution of this Action, the Parties have agreed to continue the February 26,
2026 hearing on the Motion, subject to the Court’s approval;
 	WHEREAS, if the Parties are able to finalize a formal agreement, they will file an
appropriate notice with the Court;
 	WHEREAS the Parties believe that good cause exists and it is in the interests of
judicial economy to continue the February 26, 2026 hearing on the Motion by three weeks to
March 19, 2026 or the soonest date available thereafter, to allow the Parties to continue to work
through the mediator to attempt to finalize a settlement agreement. The Parties do not intend this
Stipulation to prejudice their positions in pursuit of or opposition to the Motion.
IT IS SO STIPULATED.
Dated: February 24, 2026 	FENNEMORE LLP & FENNEMORE CRAIG,
P.C.
B21: /s/ Brandi B. Balanda
Eugene M. Pak
Stephen C. Willey
Brandi B. Balanda
Sarah Gohmann Bigelow
Attorneys for Defendant and
Counterclaimant City of Oakland, a
municipal corporation, acting by and
through its Board of Port Commissioners
(Port of Oakland)
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 3 of 6

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STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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Dated: February 24, 2026 	COOLEY LLP
By: /s/ Bobby Ghajar
Bobby Ghajar
Judd Lauter
Colette Ghazarian
Attorneys for Plaintiff and Counterclaim
Defendant City and County of San
Francisco
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 4 of 6

STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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CIVIL L.R. 5-1(i)3 ATTESTATION
I, Brandi Balanda, attest that each of the other signatories have concurred in the filing of
this document, which shall serve in lieu of their own signature on the document.
Dated: February 24, 2026 	FENNEMORE LLP & FENNEMORE CRAIG,
P.C.
By: /s/ Brandi B. Balanda
Eugene M. Pak
Stephen C. Willey
Brandi B. Balanda
Sarah Gohmann Bigelow
Attorneys for Defendant and
Counterclaimant City of Oakland, a
municipal corporation, acting by and
through its Board of Port Commissioners
(Port of Oakland)
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 5 of 6

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STIPULATION TO CONTINUE MARCH 19, 2026
HEARING ON MOTION FOR LEAVE TO FILE
SECOND AMENDED COMPLAINT [DKT. 120]
CASE NO. 3:24-CV-02311-TSH
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ORDER
PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED:
The hearing on the Plaintiff’s Motion for Leave to File Second Amended Complaint (Dkt.
120) is hereby continued to March 19, 2026 at 10:00 am.
IT IS SO ORDERED.
Dated: February 24, 2026. By:______________________________
Magistrate Judge Thomas S. Hixson
Case 3:24-cv-02311-TSH Document 135 Filed 02/24/26 Page 6 of 6