Munns et al v. Clinton et al

Filing 27

STIPULATION and ORDER 26 signed by Judge Morrison C. England, Jr., on 4/11/11, ORDERING that Plaintiffs' Oppositions to the Motions to Dismiss shall be filed with this Court no later than April 11, 2011. (Kastilahn, A)

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THE LAW OFFICES OF WILLIAM W. PALMER
WILLIAM W. PALMER (State Bar No. 146404)
575 University Ave., Suite 100
Sacramento, California 95825
Telephone : [phone]
Facsmile : [phone]
Email : [e-mail]
ZACHARY RICHTER
Trial Attorney, Civil Division
SIEGMUND FUCHS
Trial Attorney, Civil Division
United States Department of Justice
P.O. Box 7146, Ben Franklin Station
Washington, D.C. 20044
Telephone : [phone]
Facsimile : [phone]
Email : [e-mail]
Email : [e-mail]

575 University Ave., Suite 100 – Sacramento – California - 95825
TELEPHONE [phone]

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UNITED STATES DISTRICT COURT

William W. Palmer

THE LAW OFFICES OF

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EASTERN DISTRICT OF CALIFORNIA

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Case No.: 2:10-cv-000681 –MCE – EFB
MARK MUNNS, CHRISTA MUNNS
Administrators for the separate Estate of
JOSHUA MUNNS, DENNIS
DEBRABANDER, SHARON
DEBRABANDER Administrators for the
separate Estate of JOHN YOUNG, AND LORI
SILVERI Administrator for the separate Estate
of John Cote,

STIPULATION AND REQUEST FOR
EXTENSION OF TIME TO OPPOSE
DEFENDANTS’ MOTIONS TO DISMISS

On behalf of themselves as individuals and as
taxpayers,

(Hon. Judge Morrison C. England, Jr.)

Date:
Time:
Ctrm:

May 5, 2011
2:00 p.m.
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PLAINTIFFS,
vs.
HILLARY DIANE RODHAM CLINTON, in
her official capacity as UNITED STATES
SECRETARY OF STATE; JENNIFER FOO, in
her official capacity;
DEFENDANTS.
-1STIPULATION AND REQUEST TO CONTINUE THE HEARING DATE ON DEFENDANTS’
MOTION TO DISMISS

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STIPULATION

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WHEREAS, Defendants United States, Hillary Diane Rodham Clinton, and Jenny
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Foo filed and served Motions to Dismiss (the “Motions”) on March 7, 2011, and the
hearing is currently scheduled for 2:00 p.m. on May 5, 2011 in Courtroom 7 of this
Court;
WHEREAS, Plaintiffs’ oppositions to the Motions were due on or before March
24, 2011;
WHEREAS, on March 29, 2011, counsel for Plaintiffs contacted counsel for

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Defendants to request additional time to file Plaintiffs’ oppositions to the Motions and a

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continuance of the hearing date for the Motions based on family illness and

575 University Ave., Suite 100 – Sacramento – California - 95825
TELEPHONE [phone]

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William W. Palmer

THE LAW OFFICES OF

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unavailability. Further, paralegal for Plaintiffs’ counsel and the only staff member able to

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assist Plaintiffs’ counsel with the preparation of the Oppositions was unavailable. The

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paralegal was in the hospital with his four-month-old daughter who was rushed to the

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hospital and remained there for over seven days, and was treated for dehydration and

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urinary tract infection. She is now an outpatient and is still closely monitored by doctors

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and was referred to a gastrointestinal specialist in the Bay Area. As a consequence, the

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paralegal was absent and unavailable. Plaintiffs’ counsel has primary custody of his three
children, two of which were ill and had to be taken from school during the week the
opposition was due.

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WHEREAS, on April 4, 2011, this Court granted Plaintiffs’ unopposed request
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for an extension of time to file their oppositions from March 24, 2011, until April 7,
2011, based on the circumstances described above, and also granted the parties’ joint
request to move the hearing date from April 7, 2011, to May 5, 2011.

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WHEREAS, on April 6, 2011 counsel for Plaintiffs contacted counsel for

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Defendants to request additional time to file Plaintiffs’ oppositions to the Motions and a

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-2STIPULATION AND REQUEST TO CONTINUE THE HEARING DATE ON DEFENDANTS’
MOTION TO DISMISS

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continuance of the hearing date for the Motions based on the circumstances describe

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above.
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WHEREAS, Defendants do not oppose Plaintiffs’ request for an extension of time
to file their opposition;
IT IS HEREBY STIPULATED and agreed to by and between the parties, through

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their respective counsel of record, that Plaintiffs’ Oppositions to the Motions shall be

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filed with this Court no later than April 11, 2011.

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Dated: April 8, 2011

Law Offices of William W. Palmer

575 University Ave., Suite 100 – Sacramento – California - 95825
TELEPHONE [phone]

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William W. Palmer

THE LAW OFFICES OF

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By:___________/s/________________
WILLIAM W. PALMER
Attorney for Plaintiffs

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Dated: April 8, 2011

United States Department of Justice, Civil Division

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By:___________/s/________________
SIEGMUND FUCHS
Attorney for Defendants

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-3STIPULATION AND REQUEST TO CONTINUE THE HEARING DATE ON DEFENDANTS’
MOTION TO DISMISS

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ORDER
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED:

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Plaintiffs’ Oppositions to the Motions shall be filed with this Court no later than
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April 11, 2011.
Date: April 11, 2011

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__________________________________
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE

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DEAC_Signature-END:

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04if0d0-fkhfkh

575 University Ave., Suite 100 – Sacramento – California - 95825
TELEPHONE [phone]

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William W. Palmer

THE LAW OFFICES OF

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-4STIPULATION AND REQUEST TO CONTINUE THE HEARING DATE ON DEFENDANTS’
MOTION TO DISMISS