Frary et al v. County of Marin et al

Filing 33

ORDER by Magistrate Judge Maria-Elena James granting #32 Stipulation (rmm2S, COURT STAFF) (Filed on 1/31/2013)

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Thomas F. Bertrand, State Bar No. 056560
Richard W. Osman, State Bar No. 167993
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
CITY OF NOVATO, CHIEF JOSEPH KREINS,
OFFICER THOMAS MACKENZIE, OFFICER
MICHAEL DUNN and OFFICER STEPHANIE COMMISTO
David L. Fiol, State Bar No. 203546
BRENT, FIOL & NOLAN LLP
Two Embarcadero Center, 18th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
LYNNETTE FRARY AND JAMIE BALL
Charles A. Bonner, State Bar No. 85413
A. Cabral Bonner, State Bar No. 247528
BONNER & BONNER
475 Gate Five Rd, Suite 212
Sausalito, CA 94965
Telephone: [phone]
Facsimile: 415-331-2738
Attorneys for Plaintiff
HEATHER HOWARD

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LYNNETTE FRARY, et al.,
Case No. CV-12-3928 MEJ

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Plaintiffs,
v.
COUNTY OF MARIN, et al.,

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STIPULATED REQUEST TO EXTEND TIME TO
RESPOND TO FIRST AMENDED COMPLAINT;
[PROPOSED] ORDER

Defendants.
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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT
Frary v. County of Marin, et al.
U.S.D.C. Northern District of CA Case No. CV-12-3928 MEJ

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The parties in the above-captioned case, by and through their counsel of record, hereby represent
to the Court as follows:

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1.

On January 17, 2013, Plaintiffs filed their First Amended Complaint in the above-

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captioned action.

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2.

Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer

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Michael Dunn and Officer Stephanie Commisto’s last day to file a responsive pleading to the First

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Amended Complaint is currently January 31, 2013.

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3.

Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer

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Michael Dunn and Officer Stephanie Commisto intend to file an answer to the First Amended Complaint,

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but require additional time to prepare the answer. The parties have agreed to a ten (10) day extension of

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time to answer.

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4.

Plaintiffs and Defendants City of Novato, Chief Joseph Kreins, Officer Thomas

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Mackenzie, Officer Michael Dunn and Officer Stephanie Commisto stipulate to extend the time for

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Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer Michael Dunn and

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Officer Stephanie Commisto to respond to the First Amended Complaint through and including

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February 11, 2013.

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Dated: January 31, 2013

By: /s/ Richard W. Osman
Richard W. Osman
Attorneys for Defendants
CITY OF NOVATO, CHIEF JOSEPH KREINS,
OFFICER THOMAS MACKENZIE, OFFICER
MICHAEL DUNN and OFFICER STEPHANIE
COMMISTO

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Dated: January 31, 2013

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BRENT, FIOL & NOLAN LLP
By: /s/ David L. Fiol
David L. Fiol
Attorneys for Plaintiffs
LYNNETTE FRARY AND JAMIE BALL

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BERTRAND, FOX & ELLIOT

Dated: January 31, 2013

BONNER & BONNER
By: /s/ Charles A. Bonner
Charles A. Bonner
Attorneys for Plaintiff
HEATHER HOWARD

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT
Frary v. County of Marin, et al.
U.S.D.C. Northern District of CA Case No. CV-12-3928 MEJ

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PROPOSED ORDER

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Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the time for

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Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer Michael Dunn and

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Officer Stephanie Commisto to respond to the Complaint shall be extended to February 11, 2013.

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S

FO

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R NIA

ames

-Elena J

aria
Judge M

H

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RT

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UNITED STATES DISTRICT COURT JUDGE

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, 2013

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January 31,

UNIT
ED

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DATED:

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT
Frary v. County of Marin, et al.
U.S.D.C. Northern District of CA Case No. CV-12-3928 MEJ