Ramirez v. County of Alameda et al

Filing 8

ORDER by Chief Magistrate Judge Maria-Elena James granting 7 Stipulation to Extend Time To Respond to Complaint. (rmm2S, COURT STAFF) (Filed on 11/1/2012)

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Thomas F. Bertrand, State Bar No. 056560
Michael C. Wenzel, State Bar No. 215388
BERTRAND, FOX & ELLIOT
The Waterfront Building
2749 Hyde Street
San Francisco, California 94109
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants
COUNTY OF ALAMEDA, ALAMEDA COUNTY
SHERIFF'S DEPARTMENT and GREGORY AHERN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ELISA RAMIREZ, Guardian ad Litem for A.S.,
minor,

Case No. C12-4852-MEJ

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Plaintiff,

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v.

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

COUNTY OF ALAMEDA, ALAMEDA
COUNTY SHERIFF'S DEPT., GREGORY
AHERN, Sheriff,

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Defendants.

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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:
1.

On September 14, 2012, Plaintiff filed the Complaint initiating the above-captioned action

against the County of Alameda, Alameda County Sheriff’s Department and Sheriff Gregory Ahern.
2.

On September 27, 2012, Plaintiff served the Complaint on the County of Alameda,

Alameda County Sheriff’s Department and Sheriff Gregory Ahern by personal service.
3.

Defendants County of Alameda, Alameda County Sheriff’s Department and Sheriff

Gregory Ahern’s last day to file a responsive pleading to the Complaint was October 18, 2012.
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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER
Ramirez v. County of Alameda, et al., United States District Court Case No. 3:12-cv-04852-MEJ

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4.

By Order dated October 25, 2012, this Court approved the parties’ stipulation extending

defendants' time to respond to the complaint to November 1, 2012.
5.

On October 26, 2012 counsel for defendants sent meet and confer correspondence to

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plaintiff's counsel regarding requesting plaintiff dismiss certain causes of action from the complaint in an

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effort to avoid a motion to dismiss.

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6.

While the parties have agreed on most issues raised in that correspondence, counsel for

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plaintiff needs additional time to complete review of the correspondence and, if necessary, draft a first

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amended complaint.

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7.

The parties therefore stipulate to extend the time for defendants to respond to the

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Complaint through and including November 15, 2012. An extension of this length will not interfere with

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any deadlines currently pending on the Court's calendar.

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DATED: October 31, 2012

LAW OFFICES OF JOHN L. BURRIS

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By: /s/ DeWitt Lacy
John L. Burris
DeWitt Lacy
Attorneys for Plaintiff
ELISA RAMIREZ, Guardian
ad Litem for A.S., minor

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DATED: October 31, 2012

BERTRAND, FOX & ELLIOT

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By: /s/ Michael C. Wenzel
Thomas F. Bertrand
Michael C. Wenzel
Attorneys for Defendants
COUNTY OF ALAMEDA, ALAMEDA
COUNTY SHERIFF'S DEPARMENT and
GREGORY AHERN

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER
Ramirez v. County of Alameda, et al., United States District Court Case No. 3:12-cv-04852-MEJ

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ORDER

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Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the time for
Defendant to respond to the Complaint shall be extended to November 15, 2012.

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UNITED STATES CHIEF MAGISTRATE JUDGE

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UNIT
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November 1, 2012
Dated: October ___, 2012

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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER
Ramirez v. County of Alameda, et al., United States District Court Case No. 3:12-cv-04852-MEJ