Freitag v. CDC, et al

Filing 657

STIPULATION AND ORDER Extending Plaintiff's Time to Respond to Defendants' Motion to Terminate the Injunction or, Alternatively, to Modify the Injunction-Monitoring Process re #656 : Set/Reset Deadlines as to re #648 Motion to Terminate the Injunction or, Alternatively, to Modify the Injunction-Monitoring Process. Responses due by 9/10/2012. Replies due by 9/21/2012. Motion Hearing set for 10/15/2012 at 10:00 AM in Courtroom 2, 17th Floor, San Francisco before Hon. Thelton E. Henderson. Signed by Judge Thelton E. Henderson on 08/20/2012. (tmi, COURT STAFF) (Filed on 8/21/2012)

1
2
3
4
5
6

PAMELA Y. PRICE, ESQ. (STATE BAR NO. 107713)
JANE BOND MOORE, ESQ. (STATE BAR NO. 72000)
PRICE AND ASSOCIATES
A Professional Law Corporation
901 Clay Street
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
DEANNA L. FREITAG

7
8
9
10
11
12
13
14

KAMALA D. HARRIS
Attorney General of California
LYN HARLAN (STATE BAR NO. 171471)
KATHRYN ALLEN (STATE BAR NO. 137685)
1515 Clay Street, 20th Floor
P.O. Box 70550
Oakland, CA 94612-0550
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant CALIFORNIA
DEPARTMENT OF CORRECTIONS AND REHABILITATION

15
16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18
19

DEANNA L. FREITAG,

20
21

Plaintiff,
v.

22
23
24
25
26

CALIFORNIA DEPARTMENT OF
CORRECTIONS, et al
Defendants.

)
)
)
)
)
)
)
)
)
)
)

CASE NO. 3:00-CV-02278 TEH
STIPULATION AND [PROPOSED]
ORDER EXTENDING PLAINTIFF’S
TIME TO RESPOND TO
DEFENDANTS’ MOTION TO
TERMINATE THE INJUNCTION
OR, ALTERNATIVELY, TO
MODIFY THE INJUNCTIONMONITORING PROCESS
IT IS SO ORDERED AS MODIFIED

27
28

1083JBM-P200

-1_____________________________________________________________________________________
STIPULATION AND PROPOSED ORDER (C00-2278 TEH)

1

The parties, by and through their respective counsel of record, hereby stipulate that

2

Defendants’ Motion to Terminate the Injunction or, Alternatively, to Modify the Injunction-

3

Monitoring process, and all dates presently set for Plaintiff’s opposition, Defendants’ reply and the

4

hearing may be moved as set forth below. The basis for this stipulation is that Attorney Pamela Y.

5

Price’s father is extremely ill. She is presently with him and her family in Cincinnati, Ohio.

6
7
8
9

Physicians treating Attorney Price’s father believe that his condition will continue as very serious
for at least another ten (10) days.
Attorney Lyn Harlan and Attorney Jane Moore have conferred about other dates for this
motion and have agreed that the following dates are available for all parties: September 10, 2012

10
for Plaintiff’s opposition, September 21, 2012 for Defendants reply. Both parties are available on
11
12

October 8, 2012 at 10:00 a.m. for the hearing.

13
14

Dated: August 14, 2012

15

/s/ ]tÇx UA `ÉÉÜx
JANE B. MOORE, Attorney for
Plaintiff DEANNA FREITAG

16
17
18
19
20

Dated: August 14, 2012

/s/ _çÇ [tÜÄtÇ

LYN HARLAN, Attorney for
CALIFORNIA DEPARTMENT OF
CORRECTIONS AND
REHABILITATION, ET AL

21
22
23
24
25
26
27
28

1083JBM-P200

-2_____________________________________________________________________________________
STIPULATION AND PROPOSED ORDER (C00-2278 TEH)

1
2

ORDER

3
4
5

Having considered the foregoing stipulation, and good cause appearing, IT IS
SO ORDERED. The hearing shall occur on October 15, 2012, at 10:00 a.m.

6
7
8
9
10

DATE: 08/20/2012
11
12
13
14

______________________________
THELTON E. HENDERSON, JUDGE
UNITED STATES DISTRICT COURT

15
16
17
18
19
20
21
22
23
24
25
26
27
28

1083JBM-P200

-3_____________________________________________________________________________________
STIPULATION AND PROPOSED ORDER (C00-2278 TEH)