Steinhart v. County of Sonoma et al

Filing 55

SECOND STIPULATION AND ORDER RE 54 TO CONTINUE HEARING ON MOTIONS TO DISMISS AND TO STRIKE; EXTEND BRIEFING SCHEDULES; AND CONTINUE CASE MANAGEMENT CONFERENCE. Case Management Conference set for 10/27/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco. Motion Hearing set for 10/27/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 8/31/11. (cl, COURT STAFF) (Filed on 8/31/2011)

*E-Filed 8/31/11*

1 Sally Steinhart, SBN 104006
1535 Farmers Lane, #202

2 Santa Rosa, CA 95405-7525
Tel: [phone]

3 [e-mail]
4 Plaintiff in Pro Per
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

11 SALLY STEINHART,

No. CV-10-00841 RS

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SECOND 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

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Plaintiff,
v.

14 COUNTY OF SONOMA, et al.,
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Defendants.

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/

This joint stipulation is entered into by and between Plaintiff in pro per, Sally Steinhart

18 (“Plaintiff”), and Defendants the County of Sonoma, former Sheriff-Coroner William Cogbill, and
19 County employees Michael Shanahan, Brian K. Covington, Caroline Jaap, Jo Weber, Nicholas
20 Honey, Jerry Allen, Betty Johnson and Robin Smith (collectively, “County Defendants”). Through
21 this second stipulation, these parties request the Court to enter an order: (1) continuing the hearing
22 on the pending Motion to Dismiss Third Amended Complaint, and Anti-SLAPP Motion to Strike, to
23 October 27, 2011; (2) extending the briefing schedule on such Motions to permit Plaintiff to file her
24 oppositions through September 26, 2011, and for County Defendants to file their replies through
25 October 7, 2011; and (3) continuing the Case Management Conference, currently set for September
26 29, 2011, to October 27, 2011, at 1:30 p.m., to enable it to be heard at the same time as the pending
27 Motions. Defendant the State Department of Social Services and other named defendants have not
28 appeared in this action, and are not parties to this stipulation.
Second 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

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RECITALS

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A.

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

3 Complaint for Declaratory and Injunctive Relief and Damages on June 27, 2011 (Dkt. No. 46, the
4 “TAC”). In response, on July 29, 2011, County Defendants filed their Motion to Dismiss the TAC
5 (Dkt. No. 47) and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50), collectively
6 referred to herein as the “Motions”.
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B.

Pursuant to a previous stipulation of the parties approved by the Court, Plaintiff’s

8 time to file her oppositions to the Motions was extended through August 31, 2011, County
9 Defendants’ time to file their replies was extended through September 8, 2011, and the hearings
10 were continued to September 29, 2011 (Dkt. No. 53). In addition, the Court also approved the
11 parties’ stipulation to hold the initial Case Management Conference at the same time as the hearing
12 on the Motions, on September 29, 2011, at 1:30 p.m. (Id.)
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C.

Plaintiff has requested additional time in which to prepare and file her oppositions to

14 the Motions through September 26, 2011, as she is in the process of moving her office and has not
15 been able to complete such oppositions in time to meet current deadlines. County Defendants have
16 consented to Plaintiff’s requested extension of time, and Plaintiff has agreed to extend County
17 Defendants’ time in which to file their replies to the Motions through October 7, 2011. The parties
18 agree that, aside from the dates set forth in Section B, above, there are no other dates or scheduling
19 issues that affect the requested extensions of time.
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D.

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

21 the hearing on the pending Motions, currently set for September 29, 2011, be continued to October
22 27, 2011, at 1:30 p.m., and that the initial Case Management Conference be continued to that date
23 and time as well.
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WHEREFORE, the parties to this stipulation hereby agree and request entry of a Court order

25 as follows:
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Second 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

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2

STIPULATION
1.

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

3 47) and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50) be continued to October
4 27, 2011, at 1:30 p.m.
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2.

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

6 oppositions through September 26, 2011, and for County Defendants to file their replies through
7 October 7, 2011.
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3.

The Case Management Conference, currently set for September 29, 2011, be

9 continued to October 27, 2011, at 1:30 p.m. A joint case management conference statement shall be
10 filed one week prior to the conference.
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4.

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

12 from this Court, to amend this stipulation and order or otherwise.
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Respectfully submitted,

14 Dated: August 30, 2011

Bruce D. Goldstein, County Counsel

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By:

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

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18 Dated: August 30, 2011

Sally Steinhart, Plaintiff in pro per

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By:

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/s/ Sally Steinhart
Sally Steinhart

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Second 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

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[PROPOSED] ORDER
Pursuant to and in accordance with the foregoing Stipulation, and with good cause appearing,

3 it is hereby ordered as follows:
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1.

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

5 and Anti-SLAPP Motion to Strike under CCP § 425.16 (Dkt. No. 50) is continued to October 27,
6 2011, at 1:30 p.m.
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2.

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

8 oppositions through September 26, 2011, and for County Defendants to file their replies through
9 October 7, 2011.
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3.

The Case Management Conference, currently set for September 29, 2011, is continued to

11 October 27, 2011, at 1:30 p.m. A joint case management conference statement shall be filed one
12 week prior to the conference.
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IT IS SO ORDERED.

8/31/11
14 Date: _____________

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___________________________________
HONORABLE RICHARD SEEBORG
United States District Judge

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Second 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