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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 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: (415) 353-0999 Facsimile: (415) 353-0990 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: (415) 259-4420 Facsimile: (415) 373-4420 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: 415-331-3070 Facsimile: 415-331-2738 Attorneys for Plaintiff HEATHER HOWARD 19 UNITED STATES DISTRICT COURT 20 NORTHERN DISTRICT OF CALIFORNIA 21 LYNNETTE FRARY, et al., Case No. CV-12-3928 MEJ 22 23 24 Plaintiffs, v. COUNTY OF MARIN, et al., 25 STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT; [PROPOSED] ORDER Defendants. 26 27 28 1 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 1 2 The parties in the above-captioned case, by and through their counsel of record, hereby represent to the Court as follows: 3 1. On January 17, 2013, Plaintiffs filed their First Amended Complaint in the above- 4 captioned action. 5 2. Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer 6 Michael Dunn and Officer Stephanie Commisto’s last day to file a responsive pleading to the First 7 Amended Complaint is currently January 31, 2013. 8 3. Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer 9 Michael Dunn and Officer Stephanie Commisto intend to file an answer to the First Amended Complaint, 10 but require additional time to prepare the answer. The parties have agreed to a ten (10) day extension of 11 time to answer. 12 4. Plaintiffs and Defendants City of Novato, Chief Joseph Kreins, Officer Thomas 13 Mackenzie, Officer Michael Dunn and Officer Stephanie Commisto stipulate to extend the time for 14 Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer Michael Dunn and 15 Officer Stephanie Commisto to respond to the First Amended Complaint through and including 16 February 11, 2013. 17 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 18 19 20 21 22 Dated: January 31, 2013 24 25 27 28 BRENT, FIOL & NOLAN LLP By: /s/ David L. Fiol David L. Fiol Attorneys for Plaintiffs LYNNETTE FRARY AND JAMIE BALL 23 26 BERTRAND, FOX & ELLIOT Dated: January 31, 2013 BONNER & BONNER By: /s/ Charles A. Bonner Charles A. Bonner Attorneys for Plaintiff HEATHER HOWARD 2 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 1 PROPOSED ORDER 2 Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the time for 3 Defendants City of Novato, Chief Joseph Kreins, Officer Thomas Mackenzie, Officer Michael Dunn and 4 Officer Stephanie Commisto to respond to the Complaint shall be extended to February 11, 2013. 5 12 S FO LI ER R NIA ames -Elena J aria Judge M H 11 RT 10 UNITED STATES DISTRICT COURT JUDGE NO 9 , 2013 A 8 January 31, UNIT ED 7 DATED: RT U O 6 S DISTRICT TE C TA N F D IS T IC T O R C 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 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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