Alvarado, et al. vs. USA

Filing 8

STIPULATION to Extend Time in Which to Respond to Complaint (extended from 4/17/09 to 5/18/2009) and Scheduling Conference Date (Initial Scheduling Conference is continued from 5/7/09 to 6/17/2009 at 09:15 AM in Courtroom 7 (SMS) before Judge Sandra M. Snyder); ORDER re same, signed by Judge Sandra M. Snyder on 4/14/2009. (Herman, H)

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LAWRENCE G. BROWN Acting United States Attorney ALYSON A. BERG Assistant United States Attorney United States Courthouse 2500 Tulare Street, Suite 4401 Fresno, California 93721 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant United States of America

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SARA ALVARADO individually and as Guardian ad Litem for MARTIN ALVARADO, VIVIAN ALVARADO, FABIAN ALVARADO and ANGEL ALVARADO, minors, Plaintiffs, ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1:09-cv-00243 LJO-SMS STIPULATION TO EXTEND TIME IN WHICH TO RESPOND TO COMPLAINT AND SCHEDULING CONFERENCE DATE; ORDER RE SAME

14 v. 15 UNITED STATES OF AMERICA, 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28

Plaintiffs SARA ALVARADO individually and as Guardian ad Litem for MARTIN ALVARADO, VIVIAN ALVARADO, FABIAN ALVARADO and ANGEL ALVARADO, minors ("Plaintiffs") and defendant United States of America ("Defendant") (collectively "the parties") stipulate, by and through the undersigned counsel, to extend the deadline for Defendant to respond to the Complaint For Damages to and including May 18, 2009. The parties further agree to continue the date of the scheduling conference currently set for May 7, 2009 at 9:15 a.m. in Courtroom 7 of the above-entitled court to, June 17, 2009 at 9:15 a.m. in Courtroom 7. 1
STIPULATION TO EXTEND TIME IN WHICH TO RESPOND TO COMPLAINT AND SCHEDULING CONFERENCE DATE; [PROPOSED] ORDER RE SAME

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The parties base this stipulation on good cause, which includes the need for Defendant to review the allegations in the Complaint and respond accordingly. The parties agree that this

short extension of the time for the Defendant to respond will not cause any prejudice to the parties as this action was recently commenced. Accordingly, the parties stipulate and agree to continue the time for Defendant to file a responsive pleading and the scheduling conference as specified below, and base it on the above-stated good cause. The parties request the court to

endorse this stipulation by way of formal order. Old Date Defendant's response to Complaint Scheduling Conference April 17, 2009 New Date May 18, 2009

May 7, 2009 @9:15 a.m. Dept. 7

June 17, 2009 @9:15 a.m. Dept. 7

Respectfully submitted, Dated: April 6, 2009 LAWRENCE G. BROWN Acting United States Attorney

/s/ Alyson A. Berg ALYSON A. BERG Attorneys for Defendant Cornwell & Sample LLP

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(As authorized 04/06/09)

24 25 26 27 28 2 IT IS SO ORDERED. Dated: icido3 April 14, 2009

/s/Stephen R. Cornwell STEPHEN R. CORNWELL Attorney for Plaintiffs

/s/ Sandra M. Snyder UNITED STATES MAGISTRATE JUDGE

STIPULATION TO EXTEND TIME IN WHICH TO RESPOND TO COMPLAINT AND SCHEDULING CONFERENCE DATE; [PROPOSED] ORDER RE SAME