Retiree Support Group of Contra Costa County v. Contra Costa County

Filing 10

STIPULATION AND ORDER re 9 STIPULATION WITH PROPOSED ORDER To Extend Time For Filing First Responsive Pleading filed by Contra Costa County. Signed by Judge Jeffrey S. White on 3/9/12. (sis, COURT STAFF) (Filed on 3/9/2012)

Case3:12-cv-00944-JSW Document9 Filed03/08/12 Page1 of 5

1 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
2 [e-mail]
SARAH D. MOTT, SBN 148597
3 [e-mail]
CAROLINE B. BURNETT, SBN 259389
4 [e-mail]
425 Market Street, 26th Floor
5 San Francisco, California 94105
Telephone: [phone]
6 Facsimile:
[phone]
7 COUNTY COUNSEL, CONTRA COSTA COUNTY
SHARON L. ANDERSON, SBN #94814
8 [e-mail]
MARY ANN McNETT MASON, SBN #115089
9 [e-mail]
651 Pine St., 9th Floor
10 Martinez, CA 94553
Telephone: [phone]
11 Facsimile: [phone]
12 Attorneys for Defendants Contra Costa County
13

UNITED STATES DISTRICT COURT

14

NORTHERN DISTRICT OF CALIFORNIA

15
16

Retiree Support Group of Contra Costa
17 County,
18
19

Plaintiff,
v.

CASE NO. C 12-00944 (JSW)
STIPULATION TO EXTEND TIME FOR
FILING FIRST RESPONSIVE
PLEADING; [PROPOSED] ORDER
AS MODIFIED

20 Contra Costa County,
N.D. Local Rule 6-1(a)
21

Defendant.

22
23
24
25
26
27
28
4177074.2

C 12-00944 (DMR)
STIPULATION TO EXTEND TIME FOR FILING FIRST RESPONSIVE PLEADING; [PROPOSED]

Case3:12-cv-00944-JSW Document9 Filed03/08/12 Page2 of 5

1

Defendant Contra Costa County (the "County") and Plaintiff Retiree Support Group of

2 Contra Costa County ("RSG"), (collectively the "Parties"), through their respective counsel of
3 record , hereby agree and stipulate as follows.
4

1.

RSG filed and served its complaint in this action on February 24, 2012, seeking

5 declaratory and injunctive relief against the County with respect to retiree health benefits.
6

2.

The County requires additional time to prepare a response to the complaint, beyond

7 the time allotted by the Federal Rules of Civil Procedure, Rule 12.
8

3.

Pursuant to Northern District Local Rule 6-1(a), the Parties have agreed that the

9 County shall have through and including April 16, 2012 in which to file its responsive pleading
10 herein.
11

4.

The County intends to file a motion to dismiss or other motion instead of an answer

12 to the complaint (the "Motion"). The Parties request that the Court set the Motion to be heard at
13 9:00 a.m. on June 15, 2012, which is currently an available hearing date on the Court's calendar
14 and the date the Case Management Conference has been scheduled at 1:30 p.m. The Parties
11
15 stipulate that any opposition brief to the Motion shall be due on or before May 18, 2012 and any
May 22
16 reply brief shall be due on or before June 1, 2012.
17

5.

Providing this extension of time to file a responsive pleading (which amounts to a

18 31 day extension) beyond the time allotted under the Federal Rules of Civil procedure will not
19 affect any of the dates set pursuant to the Order Setting Initial Case Management Conference and
20 Requiring joint Case Management Conference Statement previously entered herein.
21
22

////

23

////

24

////

25

////

26

////

27

////

28
4177074.2

////

////
C 12-00944 (DMR)
-2STIPULATION TO EXTEND TIME FOR FILING FIRST RESPONSIVE PLEADING; [PROPOSED ORDER]

Case3:12-cv-00944-JSW Document9 Filed03/08/12 Page3 of 5

1

IT IS SO STIPULATED.

2
3

DATED: March 8, 2012

HANSON BRIDGETT LLP

4
By:
/s/ Raymond F. Lynch
RAYMOND F. LYNCH
Attorneys for Contra Costa County

5
6
7
8 DATED: March 8, 2012
9

LEWIS FEINBERG LEE RENAKER &
JACKSON, P.C.

10
11
12
13

By:
/s/ Jeffrey Lewis
JEFFREY LEWIS
Attorneys for Retiree Support Group of Contra
Costa County

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4177074.2

C 12-00944 (DMR)
-3STIPULATION TO EXTEND TIME FOR FILING FIRST RESPONSIVE PLEADING; [PROPOSED ORDER]

Case3:12-cv-00944-JSW Document9 Filed03/08/12 Page4 of 5

ORDER

1
2
3
4
5

PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED.
AS MODIFIED ABOVE, IT IS SO ORDERED.
9
DATED: March ___, 2012

______________________________
HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT COURT

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
4177074.2

C 12-00944 (DMR)
-4STIPULATION TO EXTEND TIME FOR FILING FIRST RESPONSIVE PLEADING; [PROPOSED ORDER]