Steinhart v. County of Sonoma et al

Filing 53

STIPULATION AND ORDER RE 52 TO CONTINUE HEARING ON MOTIONS TO DISMISS AND TO STRIKE AND EXTEND BRIEFING SCHEDULES AND TO CONTINUE CASE MANAGEMENT CONFERENCE. Case Management Conference set for 9/29/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco. Motion Hearing set for 9/29/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg.Signed by Judge Richard Seeborg on 8/12/11. (cl, COURT STAFF) (Filed on 8/12/2011)

*E-Filed 8/12/11*

BRUCE D. GOLDSTEIN, State Bar No. 135970
County Counsel
ANNE L. KECK, State Bar No. 136315
Deputy County Counsel
County of Sonoma
575 Administration Drive, Room 105A
Santa Rosa, California 95403-2815
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
Attorneys for Defendants the County
of Sonoma, Former Sheriff-Coroner William
Cogbill, and County employees Michael
Shanahan, Brian K. Covington, Caroline
Japp, Jo Weber, Nicholas Honey, Jerry
Allen, Betty Johnson, and Robin Smith
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
SALLY STEINHART,

No. CV-10-00841 RS

Plaintiff,

STIPULATION FOR ORDERS TO: (1)
CONTINUE HEARING ON MOTIONS
TO DISMISS AND TO STRIKE; (2)
EXTEND BRIEFING SCHEDULES;
AND (3) CONTINUE CASE
MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

v.
COUNTY OF SONOMA, et al.,
Defendants.

/
This joint stipulation is entered into by and between Plaintiff in pro per, Sally Steinhart
(“Plaintiff”), and Defendants the County of Sonoma, former Sheriff-Coroner William Cogbill, and
County employees Michael Shanahan, Brian K. Covington, Caroline Jaap, Jo Weber, Nicholas
Honey, Jerry Allen, Betty Johnson and Robin Smith (collectively, “County Defendants”). Through
this stipulation, these parties request the Court to enter an order: (1) continuing the hearing on the

Stipulation for Orders to: (1) Continue Hearing
on Motions to Dismiss and to Strike; (2) Extend
Briefing Schedule; et al.;[Proposed] Order

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USDC Case No. CV-10-00841 RS

pending Motion to Dismiss Third Amended Complaint, and Anti-SLAPP Motion to Strike, to
September 29, 2011; (2) extending the briefing schedule on such Motions to permit Plaintiff to file
her oppositions through August 31, 2011, and for County Defendants to file their replies through
September 8, 2011; and (3) continuing the Case Management Conference, currently set for August
25, 2011, to September 29, 2011, at 1:30 p.m., so that it may be heard at the same time as the
pending motions. Defendant the State Department of Social Services and other named defendants
have not appeared in this action, and are not parties to this stipulation.
RECITALS
A.

Plaintiff initiated this action on February 26, 2010, and later filed her Third Amended

Complaint for Declaratory and Injunctive Relief and Damages on June 27, 2011 (Dkt. No. 46, the
“TAC”). In response, on July 29, 2011, County Defendants filed their Motion to Dismiss the TAC
(Dkt. No. 47) and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50), collectively
referred to herein as the “Motions”. Both of the Motions are currently set for hearing on September
8, 2011, at 1:30 p.m.
B.

Pursuant to Civil Local Rules, Plaintiff’s oppositions to the Motions are due to be

filed and served on or before August 12, 2011; County Defendants’ replies are due to be filed seven
days after filing/service of the oppositions.
C.

County Defendants have agreed to provide Plaintiff with additional time in which to

file and serve her oppositions to the pending Motions through August 31, 2011. In addition, Plaintiff
has agreed to extend the time in which County Defendants may file their replies to such oppositions
through September 8, 2011.
D.

Based on the requested extension of this briefing schedule, the parties also request

that the hearing on the pending Motions, currently set for September 8, 2011, be continued to

Stipulation for Orders to: (1) Continue Hearing
on Motions to Dismiss and to Strike; (2) Extend
Briefing Schedule; et al.;[Proposed] Order

2

USDC Case No. CV-10-00841 RS

September 29, 2011, at 1:30 p.m., which will provide the Court with additional time in which to
review the papers.
E.

To conserve the resources of the parties and the Court, the parties further request the

Court to continue the Case Management Conference, currently set for August 24, 2011, to September
29, 2011, at 1:30 p.m., so that it may be held at the same time as the hearings on the pending
Motions.
WHEREFORE, the parties to this stipulation hereby agree and request entry of a Court order
as follows:

Stipulation for Orders to: (1) Continue Hearing
on Motions to Dismiss and to Strike; (2) Extend
Briefing Schedule; et al.;[Proposed] Order

3

USDC Case No. CV-10-00841 RS

STIPULATION
1.

The hearing on County Defendants’ pending Motion to Dismiss the TAC (Dkt. No.

47) and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50) be continued to September
29, 2011, at 1:30 p.m.
2.

The briefing schedule on such Motions be extended to permit Plaintiff to file her

oppositions through August 31, 2011, and for County Defendants to file their replies through
September 8, 2011.
3.

The Case Management Conference, currently set for August 25, 2011, be continued to

September 29, 2011, at 1:30 p.m. A joint case management conference statement shall be filed one
week prior to the conference.
4.

This stipulation does not prevent or preclude the parties from seeking additional relief

from this Court, to amend this stipulation and order or otherwise.
Respectfully submitted,
Dated: August 12, 2011

Bruce D. Goldstein, County Counsel
By:

Dated: August 12, 2011

Sally Steinhart, Plaintiff in pro per
By:

Stipulation for Orders to: (1) Continue Hearing
on Motions to Dismiss and to Strike; (2) Extend
Briefing Schedule; et al.;[Proposed] Order

/s/ Anne L. Keck
Anne L. Keck, Deputy County Counsel
Attorneys for County Defendants

/s/ Sally Steinhart
Sally Steinhart

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USDC Case No. CV-10-00841 RS

[PROPOSED] ORDER
Pursuant to and in accordance with the foregoing Stipulation, and with good cause appearing,
it is hereby ordered as follows:
1.

The hearing on County Defendants’ pending Motion to Dismiss the TAC (Dkt. No. 47)

and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50) is continued to September 29,
2011, at 1:30 p.m.
2.

The briefing schedule on such Motions is extended to permit Plaintiff to file her

oppositions through August 31, 2011, and for County Defendants to file their replies through
September 8, 2011.
3.

The Case Management Conference, currently set for August 25, 2011, is continued to

September 29, 2011, at 1:30 p.m. A joint case management conference statement shall be filed one
week prior to the conference.
IT IS SO ORDERED.
8/12/11
Date: _____________

Stipulation for Orders to: (1) Continue Hearing
on Motions to Dismiss and to Strike; (2) Extend
Briefing Schedule; et al.;[Proposed] Order

___________________________________
HONORABLE RICHARD SEEBORG
United States District Judge

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USDC Case No. CV-10-00841 RS