3:25-cv-01606•Block v. San Francisco Unified School District et al
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER TO WITHDRAW WITHOUT PREJUDICE Kenneth Block v. San Francisco Unified School District, et al. Case No.: 3:25-cv-01606-LJC Eugene B. Elliot, State Bar No. 111475 Ethan M. Lowry, State Bar No. 278831 Corey C. Wilson, State Bar No. 332800 Ilana S. Shoyket, State Bar No. 352744 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL 2749 Hyde Street San Francisco, California 94109 Telephone: (415) 353-0999 Facsimile: (415) 353-0990 Email: eelliot@bfesf.com elowry@bfesf.com cwilson@bfesf.com ishoyket@bfesf.com Attorneys for Defendants SAN FRANCISCO UNIFIED SCHOOL DISTRICT and MICHAEL ESSIEN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA KENNETH BLOCK, Plaintiff, v. SAN FRANCISCO UNIFIED SCHOOL DISTRICT, MICHAEL ESSIEN, and DOES 2- 100, inclusive, Defendants. Case No. 3:25-cv-01606-LJC STIPULATION AND ORDER TO WITHDRAW DEFENDANTS SAN FRANCISCO UNIFIED SCHOOL DISTRICT AND MICHAEL ESSIEN’S MOTION TO DISMISS AND MOTION TO STRIKE PLAINTIFF’S SECOND AMENDED COMPLAINT WITHOUT PREJUDICE Hon. Lisa J. Cisneros John A. Shepardson LAW OFFICE JOHN A. SHEPARDSON 125 E Sunnyoaks Avenue, Suite 104 Campbell, California 95008 Tel: (408) 395-3701 Email: john@shepardsonlaw.com Attorney for Plaintiff KENNETH BLOCK Case 3:25-cv-01606-LJC Document 36 Filed 02/17/26 Page 1 of 4
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 STIPULATION AND ORDER TO WITHDRAW WITHOUT PREJUDICE Kenneth Block v. San Francisco Unified School District, et al. Case No.: 3:25-cv-01606-LJC Plaintiff KENNETH BLOCK and Defendants SAN FRANCISCO UNIFIED SCHOOL DISTRICT (the “DISTRICT”); and MICHAEL ESSIEN (collectively with the DISTRICT, “Defendants,” Plaintiff and Defendants, collectively, the “Parties”), by and through their attorneys of record, hereby stipulate to the following: WHEREAS, Defendants previously filed a Motion to Dismiss and Motion to Strike Plaintiff’s Complaint (the “Motions”). WHEREAS, the Parties desire to engage in a good-faith meet and confer process regarding the pleading issues raised in the Motions. WHEREAS, Defendants agree to withdraw the Motions without prejudice, and without waiver of any arguments, defenses, objections, or rights. WHEREAS, if the Parties are unable to resolve the pleading issues through meet and confer, Defendants reserve the right to refile a Motion to Dismiss and/or Motion to Strike, or otherwise respond to the operative complaint, in accordance with the Federal Rules of Civil Procedure on February 18, 2026. NOW, THEREFORE, for good cause as set forth above, the Parties, through their respective counsel of record, DO STIPULATE AND AGREE as follows: Defendants’ Motion to Dismiss and Motion to Strike are WITHDRAWN WITHOUT PREJUDICE. The Parties shall meet and confer in good faith regarding the pleading issues raised in the withdrawn Motions. IT IS SO STIPULATED. Dated: February 4, 2026 LAW OFFICE JOHN A. SHEPARDSON By: /s/ John A. Shepardson John A. Shepardson Attorney for Plaintiff KENNETH BLOCK Case 3:25-cv-01606-LJC Document 36 Filed 02/17/26 Page 2 of 4
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION AND ORDER TO WITHDRAW WITHOUT PREJUDICE Kenneth Block v. San Francisco Unified School District, et al. Case No.: 3:25-cv-01606-LJC Dated: February 4, 2026 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL By: /s/ Corey C. Wilson Eugene B. Elliot Ethan M. Lowry Corey C. Wilson Ilana S. Shoyket Attorneys for Defendants SAN FRANCISCO UNIFIED SCHOOL DISTRICT and MICHAEL ESSIEN ATTORNEY ATTESTATION I hereby attest that I have been authorized by counsel to show their signature on this document as /s/. Dated: February 4, 2026 By: /s/ Corey C. Wilson Corey C. Wilson Case 3:25-cv-01606-LJC Document 36 Filed 02/17/26 Page 3 of 4
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 STIPULATION AND ORDER TO WITHDRAW WITHOUT PREJUDICE Kenneth Block v. San Francisco Unified School District, et al. Case No.: 3:25-cv-01606-LJC [PROPOSED] ORDER AS MODIFIED Having reviewed the stipulation of counsel herein, IT IS HEREBY ORDERED that the Defendants’ Motion to Dismiss and Motion to Strike are WITHDRAWN WITHOUT PREJUDICE. The Parties shall meet and confer in good faith regarding the pleading issues raised in the withdrawn Motions. Defendants shall respond to the operative complaint on February 25 18, 2026. IT IS SO ORDERED DATED: February 17, 2026 ____________________________________________ UNITED STATES DISTRICT COURT JUDGE Case 3:25-cv-01606-LJC Document 36 Filed 02/17/26 Page 4 of 4
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