Bauldry v. Town of Danville et al

Filing 54

ORDER by Judge Susan Illston granting 53 Stipulation. THEREFORE, the Stipulating Parties request that the Court extend the deadline for Daggett to respond to Plaintiffs Second Amended Complaint from February 8, 2013 to, and including, February 22, 2013. (tfS, COURT STAFF) (Filed on 2/12/2013)

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George D. Niespolo (SBN 72107)
Allegra A. Jones (SBN 236518)
DUANE MORRIS LLP
Spear Tower
One Market Plaza, Suite 2200
San Francisco, CA 94105-1127
Telephone: [phone]
Facsimile: 415.957.3001
E-mail: [e-mail]
[e-mail]
Attorneys for Defendant
MONA DAGGETT

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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LANE BAULDRY,
Plaintiff,

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Case No.: 3:12-cv-03943-SI

v.
TOWN OF DANVILLE, COUNTY OF CONTRA
COSTA, CITY OF PIEDMONT, Government
Entities, MONA DAGGETT, CHRISTOPHER
BUTLER, DEPUTY STEPHEN TANABE,
DEPUTY TOM HENDERSON, SERGEANT
ANDY WELLS and DOES 1 to 50, inclusive,

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JOINT STIPULATION AND
[PROPOSED] ORDER REGARDING
FURTHER EXTENSION OF TIME
FOR DEFENDANT MONA DAGGETT
TO RESPOND TO PLAINTIFF’S
SECOND AMENDED COMPLAINT

Defendants.

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Plaintiff Lane Bauldry (“Plaintiff”) and Defendant Mona Daggett (“Daggett”) (collectively
the “Stipulating Parties”) hereby stipulate as follows:
WHEREAS, pursuant to the Stipulation and Order regarding Amendment of Complaint and

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Responses Thereto dated December 17, 2012 (“Stipulation and Order”), Plaintiff filed his second

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amended complaint, entitled “Amended Complaint for Damages for Violations of Civil Rights and

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Other Wrongs” (hereinafter “Second Amended Complaint”), on January 4, 2013;

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WHEREAS, pursuant to the Stipulation and Order, and a further stipulation and order of the

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Court dated January 28, 2013, Daggett’s current deadline for responding to the Second Amended

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Complaint is February 8, 2013;
DM1\3714857.1

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STIPULATION RE: TIME TO RESPOND TO SECOND AMENDED COMPLAINT

CASE NO. 3:12-CV-03943-SI

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WHEREAS, since Plaintiff filed Second Amended Complaint, the Stipulating Parties have

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continued to discuss this action and have agreed to extend the deadline for Daggett to answer or

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otherwise respond to the Second Amended Complaint to, and including, February 22, 2013;

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WHEREAS, an extension of time for responding to the Second Amended Complaint is

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supported by good cause as it will not prejudice any party to this action and does not interfere with

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any court-mandated deadlines;

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THEREFORE, the Stipulating Parties request that the Court extend the deadline for Daggett

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to respond to Plaintiff’s Second Amended Complaint from February 8, 2013 to, and including,

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February 22, 2013.

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IT IS SO STIPULATED.
Dated: February 8, 2013

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DUANE MORRIS LLP
By: /s/ Allegra A. Jones
Allegra A. Jones
Attorneys for Defendant
MONA DAGGETT

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Dated: February 8, 2013

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THE HALEY LAW OFFICES
By: /s/ Matthew Haley
Matthew Haley
Attorneys for Plaintiff
LANE BAULDRY

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ATTESTATION: Pursuant to Civil L.R. 5-1(i)(3), the filer attests that concurrence in the
filing of this document has been obtained from each of the other signatories thereto.

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ORDER

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IT IS SO ORDERED.

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Dated: February ____, 2013
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___________________________________
JUDGE OF THE U.S. DISTRICT COURT

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DM1\3714857.1

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STIPULATION RE: TIME TO RESPOND TO SECOND AMENDED COMPLAINT

CASE NO. 3:12-CV-03943-SI