Pollar et al v. County of Alameda et al

Filing 75

STIPULATION AND ORDER. Signed by Magistrate Judge Bernard Zimmerman on 2/3/2010. (bzsec, COURT STAFF) (Filed on 2/3/2010)

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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 ROBERT R. POWELL, ESQ. CSB#159747 DENNIS R. INGOLS, ESQ. CSB#236458 LAW OFFICES OF ROBERT R. POWELL 925 West Hedding Street San José, California 95126 T: 408-553-0200 F: 408-553-0203 Attorneys for Plaintiffs DANIELLE POLLAR, SHALAWN POLLAR as Guardian Ad Litem for J.A., a minor IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA DANIELLE POLLAR, et al., Plaintiffs, vs. COUNTY OF ALAMEDA, et al., Defendants. _____ ) ) ) ) ) ) ) ) ) ) Case No. 08-04196 BZ STIPULATION FOR AN ORDER TO EXTEND BRIEFING DEADLINES The parties hereto, by and through their respective counsel, do hereby stipulate and agree as set forth below on the following recital of facts and request this court order same: 1. The current deadline for Plaintiffs' Oppositions to the Amended Motions for Summary Judgment filed by the City Defendants (Docket #62) and County Defendants (Docket #66) is Friday, February 5, 2010, per Stipulation and Order (Docket #59). 2. Plaintiffs will file the Opposition to the City Defendants' Motion for Summary Judgment by the aforementioned deadline. 1 Stipulation and Order re: Extend Briefing Deadlines Pollar v. County of Alameda, et al. (Case No. 08-04196 BZ 1 2 3 4 5 6 3. Plaintiffs' counsel will not be able to file Plaintiffs' Opposition to County Defendants' Motion for Summary Judgment by the deadline, due to two ongoing juvenile dependency trials, and a family law trial. 4. First, in the case of Andrea N., Jadyn N., Ravyn N., Aaliyah K., Jasmine K., Gina K., Case #: 228331 through 228335, 228808, in Sacramento County Superior Court, the trial has been spread out over several days, with numerous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 delays and continuances, and has simply run longer than counsel originally estimated.1 The case has at least one days of trial remaining. 5. Second, in Charley P., Kaylee R., Case # JD19508, JD19509, Plaintiffs' counsel will be in trial at least half of the day on Tuesday, February 2, 2010, in Santa Clara County Superior Court. 6. Third, in Delfino v. Collins, Case# 1-93 CP 001783, Plaintiffs' counsel will be in trial on Friday, February 5, 2010, in Santa Clara County Superior Court. BASED on the foregoing recitals, the parties stipulate and request the court order that: 1. The current deadline for Plaintiffs' Opposition to County Defendants' Motion for Summary Judgment is hereby continued from Friday, February 5, 2010, to Monday, February 8, 2010. 2. The current deadline for County Defendants' optional Reply brief is extended from Friday, February 19, 2010, to Monday, February 22, 2010. 2 Stipulation and Order re: Extend Briefing Deadlines Pollar v. County of Alameda, et al. (Case No. 08-04196 BZ 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 IT IS SO STIPULATED. Dated: 2/2/10 ___/S/ Robert R. Powell_______ ROBERT R. POWELL, ESQ. Attorney for Plaintiffs __ /S/ Rebecca Widen_________ REBECCA WIDEN, ESQ. Attorney for County of Alameda, and Individually Named Defendant Employees of the County of Alameda ___/S/ Patrick Co_____ _______ Patrick Co Attorney for City of Hayward, Sam Sander and Mike Edwards [PROPOSED] ORDER Based on the foregoing stipulation, and good cause appearing therefore, the Court hereby adopts the stipulation of the parties and orders as follows: 1. The current deadline for Plaintiffs' Opposition to County Defendants' Motion for Summary Judgment is hereby continued from Friday, February 5, 2010, to Monday, February 8, 2010. 2. The current deadline for County Defendants' optional Reply brief is extended from Friday, February 19, 2010, to Monday, February 22, 2010. Dated: 2/2/10 Dated: 2/2/10 IT IS SO ORDERED. 3 2 Dated: ____/____/10 ____________________________ JUDGE OF THE U.S. DISTRICT COURT FOR THE NORTHERN DISTRICT- SAN FRANCISCO In juvenile dependency matters, it is common for the court to assign separate case numbers for each child in a family, though they are heard as one single case. 3 Stipulation and Order re: Extend Briefing Deadlines Pollar v. County of Alameda, et al. (Case No. 08-04196 BZ 1

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