City and County of San Francisco v. City of Oakland

STIPULATION RE H EARING ON MOTION FOR
LEAVE TO F ILE SAC
C ASE N O.: 3:24-CV-02311-TSH
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[Full Counsel Listing on Signature Page]
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CITY AND COUNTY OF SAN FRANCISCO,
Plaintiff,
v.
CITY OF OAKLAND AND PORT OF
OAKLAND,
Defendant.
Case No. 3:24-CV-02311-TSH
STIPULATION TO CONTINUE
HEARING ON MOTION FOR LEAVE
TO FILE SECOND AMENDED
COMPLAINT [DKT. 120]
AND RELATED COUNTERCLAIM
Case 3:24-cv-02311-TSH Document 131 Filed 12/17/25 Page 1 of 5

1 STIPULATION RE H EARING ON MOTION FOR
LEAVE TO F ILE SAC
C ASE N O.: 3:24-CV-02311-TSH
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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, the hearing on the Motion is noticed for December 18, 2025 at 10:00 a.m.,
which the Court converted to a Zoom hearing (Dkt. 129);
• 	WHEREAS, on December 16, 2025, the Parties participated in an over twelve-hour
mediation before a JAMS mediator, which resulted in a term sheet to be reduced to a final
settlement agreement and for which the Parties are scheduling and seeking respective board
approval to finalize;
• 	WHEREAS, the Parties intend to file an appropriate notice with the Court if the proposed
settlement terms are ultimately approved after execution of a final settlement agreement and
further to the terms therein;
• 	WHEREAS, in the meantime, consistent with the agreed-upon terms, and to avoid
potentially unnecessary expenditures and events that may interfere with the resolution of
this Action, the Parties have agreed to continue the hearing on the Motion, subject to the
Court’s approval;
• 	WHEREAS the Parties believe that good cause exists and it is in the interests of judicial
economy to continue the hearing on the Motion to allow the Parties to finalize a settlement
agreement.
Case 3:24-cv-02311-TSH Document 131 Filed 12/17/25 Page 2 of 5

2 STIPULATION RE H EARING ON MOTION FOR
LEAVE TO F ILE SAC
C ASE N O.: 3:24-CV-02311-TSH
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COOLEY LLP
A TTORNEYS AT L AW
Therefore, the Parties respectfully request that this Court enter the attached proposed
order continuing the hearing on the Motion to January 22, 2026, or as soon thereafter as is
convenient for the Court. The Parties do not intend this Stipulation to prejudice their positions in
pursuit of or opposition to the Motion.
IT IS SO STIPULATED.
Dated: December 17, 2025 	COOLEY LLP
By: 	/s/ Bobby Ghajar____________________
Bobby Ghajar
Judd Lauter
John Hemann
Ryan Stevens
Jessica Williams
Attorneys for Plaintiff and Counterclaim
Defendant City and County of San
Francisco
Dated: December 17, 2025 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 131 Filed 12/17/25 Page 3 of 5

3 STIPULATION RE H EARING ON MOTION FOR
LEAVE TO F ILE SAC
C ASE N O.: 3:24-CV-02311-TSH
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CIVIL L.R. 5-1(i)(3) ATTESTATION
I, Bobby Ghajar, attest that each of the other signatories have concurred in the filing of
this document, which shall serve in lieu of their own signatures on the document.
Dated: December 17, 2025 	COOLEY LLP
By: 	/s/ Bobby Ghajar
Bobby Ghajar
John Hemann
Judd Lauter
Jessica Williams
Attorneys for Plaintiff and Counterclaim
Defendant
CITY AND COUNTY OF SAN FRANCISCO
Case 3:24-cv-02311-TSH Document 131 Filed 12/17/25 Page 4 of 5

4 STIPULATION RE H EARING ON MOTION FOR
LEAVE TO F ILE SAC
C ASE N O.: 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 January 22, 2026 at 10:00 a.m.
IT IS SO ORDERED.
Dated: December 17, 2025. By:______________________________
Magistrate Judge Thomas S. Hixson
Case 3:24-cv-02311-TSH Document 131 Filed 12/17/25 Page 5 of 5