Doss v. County of Alameda

United States District Court for the Northern District of California

Doss v. County of Alameda

Trial Court Opinion

1 2 3 4 5 IN THE UNITED STATES DISTRICT COURT 6 FOR THE NORTHERN DISTRICT OF CALIFORNIA 7 8 BARBARA DOSS, et al., Case No. 19-cv-07940-CRB

9 Plaintiffs,

ORDER REGARDING 10 v. AUTOMATIC STAY

11 COUNTY OF ALAMEDA, et al., 12 Defendants.

13 On November 15, 2024, Defendant Wellpath, Inc. filed a suggestion of bankruptcy 14 and notice of stay (dkt. 148), in which Wellpath indicated that it had filed for chapter 11 15 bankruptcy in the Southern District of Texas. Pursuant to section 362 of the Bankruptcy 16 Code, Judge Alfredo Pérez of the U.S. Bankruptcy Court for the Southern District of Texas 17 entered an automatic stay of any proceedings against Wellpath. That stay applies here. 18 Then, on November 26, 2024, Defendant Guadalupe Garcia filed a suggestion of 19 bankruptcy and notice of stay (dkt. 149) in which she raised the same stay order from 20 Judge Pérez but asserted that it should operate as a stay of this case “in its entirety, 21 including the plaintiffs’ claims against the non-Debtor defendants [i.e., Defendants other 22 than Wellpath].” Garcia quotes the following language from Judge Pérez’s order: “The 23 lawsuits are stayed in their entirety, including the plaintiffs’ claims against the Non-Debtor 24 Defendants, on an interim basis pursuant to section 362 of the Bankruptcy Code.” Am. 25 Interim Order Enforcing the Auto. Stay at 2, In re Wellpath Holdings, Inc., Case No. 24- 26 90533 (ARP) (Bankr. S.D. Tex. Nov. 12, 2024), ECF 69. But Judge Pérez’s order makes 27 clear that capitalized terms like “Non-Debtor Defendants” are defined terms of art that 1 motion defines “Non-Debtor Defendants” with yet more defined terms and more cross- 2 references to other documents, so it is unclear whether it applies to Garcia. Mot. for Entry 3 of Interim & Final Orders to Enforce the Auto. Stay or in the Altern. Extend the Auto. Stay 4 to Non-Debtor Defs. at 2, Wellpath Holdings (Bankr. S.D. Tex. Nov. 12, 2024), ECF 17.1 5 The Court will not wade through the morass of bankruptcy filings to determine 6 whether Judge Pérez’s stay order applies to any defendants other than Wellpath in this 7 litigation. That is unnecessary. The Court retains inherent authority “to enter a stay of an 8 action before it, pending resolution of independent proceedings which bear upon the case.” 9 Mediterranean Enters., Inc. v. Ssangyong Corp.,

708 F.2d 1458

, 1465 (9th Cir. 1983) 10 (citation omitted). Many of Plaintiffs’ claims in this case arise from similar facts and 11 similar legal arguments such that a partial stay would require the parties to relitigate the 12 same issues once the bankruptcy stay is lifted. That would be inefficient for everyone 13 involved. See J & J Sports Prods., Inc. v. Brar, No. 09-CV-3394-GEB-EFB,

2012 WL 14

4755037, at *2 (E.D. Cal. Oct. 3, 2012); HML Holdings, LLC v. Romero, No. 21-CV-380- 15 BAS-BLM,

2021 WL 4751168

, at *2–3 (S.D. Cal. Oct. 12, 2021). 16 The Court therefore STAYS all proceedings in this matter pending resolution of 17 Wellpath’s bankruptcy petition. Upon termination of the bankruptcy proceeding or an 18 order granting relief from the automatic stay, the parties shall, within 14 days, file a status 19 report in this matter. 20 IT IS SO ORDERED. 21 Dated: December 3, 2024 CHARLES R. BREYER 22 United States District Judge 23 24 1 While defined terms may be useful shorthand while drafting, lawyers should take care 25 not to overuse them, especially in proposed orders when finding the definitions requires cross-referencing to various briefs and declarations. After all, someone eventually needs 26 to read and understand court orders—and lawyers’ briefs, for that matter. A complicated web of cross-references wastes courts’ and lawyers’ time (and clients’ money); it also 27 increases, rather than decreases, the risk of misinterpretation. Cf. Richard A. Posner,

Reference

Status
Unknown