Haines v. Brand et al

Filing 23

STIPULATION AND ORDER EXTENDING TIME TO RESPOND re 22 Stipulation filed by Harvey Tureck, City of Berkeley. Signed by Judge Edward M. Chen on 7/7/11. (bpf, COURT STAFF) (Filed on 7/7/2011)

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ZACH COWAN, City Attorney
KRISTY VAN HERICK, Deputy City Attorney
[e-mail]
2180 Milvia Street, Fourth Floor
Berkeley, CA 94704
TELE: [phone]
FAX.: [phone]

SBN 96372
SBN 178685

Attorneys for Defendants
CITY OF BERKELEY, HARVEY TURECK

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MARK HAINES
[e-mail]
3126 Shattuck Avenue
Berkeley, CA 94705
TELE: [phone] (Message Phone)

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Appearing Pro Se
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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MARK HAINES,

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NO. C11-01335 EMC

Plaintiff,
vs.

STIPULATION AND [PROPOSED]
ORDER GRANTING EXTENSION OF
DARYL B. BRAND, MFT, individually and in TIME FOR DEFENDANT HARVEY
her official capacity; THE CITY OF
TURECK TO FILE RESPONSIVE
BERKELEY, a municipality; BETH
PLEADING
MEYERSON, in her official capacity;
KAREN TRIBBLE, in her official capacity;
DAVID WEE, LCSW, individually and in his
official capacity; HARVEY S. TURECK,
individually and in his official capacity; FRED
MEDRANO, individually and in his official
capacity; JANE DOE #1, individually and in
her official capacity; and DOES #2 through 12,
in their individual and official capacities,

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Defendants.

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IT IS HEREBY STIPULATED by and between plaintiff Mark Haines, appearing pro se,

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and defendant Harvey Tureck (“defendant Tureck”), through the Berkeley City Attorney’s

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Office, to extend the time for defendant Tureck to file a responsive pleading from July 7, 2011 to

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July 22, 2011.
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STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME FOR DEFENDANT
HARVEY TURECK TO FILE RESPONSIVE PLEADING ~ C11-01335 EMC

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There is good cause for the stipulation to extend time as follows: defendant Tureck was

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served with the original Complaint on June 16, 2011, and the City of Berkeley received a copy of

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the original Complaint from the U.S. Marshall’s Office on July 1, 2011. Plaintiff has filed a First

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Amended Complaint, which he provided to counsel for defendant Tureck and the City of

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Berkeley by email on July 1, 2011. This extension will provide defendant Tureck time to

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analyze and prepare a response to the First Amended Complaint. This extension will also allow

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for the filing of a joint responsive pleading.

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Thus, the parties stipulate and agree that defendant Tureck’s responsive pleading may be

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filed no later than July 22, 2011. The parties are not making this request for any improper

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purpose, including undue delay. Moreover, as noted above, neither party would suffer any

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prejudice as the parties have stipulated to this request.

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SO STIPULATED.

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Respectfully submitted:

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ZACH COWAN, City Attorney
KRISTY VAN HERICK, Deputy City Attorney

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Dated:

July 6, 2011.

By:

/s/

KRISTY VAN HERICK, Deputy City Attorney
Attorneys for Defendants City of Berkeley and
Harvey Tureck

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Respectfully submitted:

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Dated:

July 6, 2011.

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By:
/s/
MARK HAINES
Plaintiff Appearing Pro Se

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__________________________________
DERED
SO OR
EDWARDT IS
I M. CHEN
United States District Court Judge

NO

n
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M. Che
Edward
STIPULATION AND [PROPOSED] ORDER GRANTING EXTENSION OF TIME FOR DEFENDANT
Judge
HARVEY TURECK TO FILE RESPONSIVE PLEADING ~ C11-01335 EMC

RT

FO

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7/7/11
Dated: ______________________

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LI

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CT
C

R NIA

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ES
AT
T

RT
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PURSUANT TO STIPULATION, IT IS SO ORDERED.STRI
DI

UNIT
ED

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