Rodriguez v. Aitken et al

Filing 15

STIPULATION AND ORDER Extending Time for Defendant Sonoma County Sheriff to Respond to Complaint. Signed by Judge Samuel Conti on 03/12/2013. (tmi, COURT STAFF) (Filed on 3/12/2013)

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1 2 3 4 5 BRUCE D. GOLDSTEIN, State Bar No. 135970 County Counsel ANNE L. KECK, State Bar No. 136315 Deputy County Counsel Office of the Sonoma County Counsel 575 Administration Drive, Room 105A Santa Rosa, CA 95403-2815 Telephone: (707) 565-2421 Facsimile: (707) 565-2624 E-mail: anne.keck@sonoma-county.org 6 7 Attorneys for Defendant Sonoma County Sheriff Steve Freitas 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 LUIS M. RODRIGUEZ, 12 Plaintiff, 13 14 15 STIPULATION REQUESTING ENTRY OF AN ORDER EXTENDING THE TIME FOR DEFENDANT SONOMA COUNTY SHERIFF TO RESPOND TO THE COMPLAINT; PROPOSED ORDER v. TIMOTHY AITKEN, et al., Defendants. 16 17 Case No. cv-13-0551 / This stipulation and request for entry of an order is entered into by and between Plaintiff Luis 18 19 the purpose of extending the time for the Sheriff to respond to the Complaint. Other named 20 defendants are not parties to this stipulation. The terms and provisions of this stipulation and request 21 for an order are set forth below. RECITALS 22 23 A. Plaintiff filed his Complaint for Damages herein on February 7, 2013, seeking 24 damages related to the issuance and enforcement of an immigration detainer against him. Plaintiff 25 effectuated service of the Complaint on the Sheriff on or about February 14, 2013. As of the date of 26 this stipulation, no defendant has yet filed a response to the Complaint. 27 28 STIPULATION EXTENDING TIME FOR SONOMA COUNTY SHERIFF TO RESPOND TO COMPLAINT; PROPOSED ORDER 1 CV-13-0551 1 B. 2 March 7, 2013. The Sheriff intends to file a motion to dismiss in response to the Complaint, and has 3 so informed Plaintiff s counsel. 4 C. 5 deadline for filing a motion to dismiss in response to the Complaint. Plaintiff s counsel have agreed 6 to 7 March 21, 2013. This extension of time will not interfere with any other dates that have been set in 8 this matter. 9 10 request to extend the date on which a response is due to the Complaint to WHEREFORE, the parties to this stipulation hereby agree and request entry of a court order as follows: STIPULATION 11 12 13 14 15 1. Defendant Sonoma County Sheriff Steve Freitas shall have through and including March 21, 2013, to file a response to the Complaint. 2. This stipulation does not prevent or preclude the parties from seeking additional relief from this Court, to amend this stipulation and order or otherwise. 16 17 Respectfully submitted, Dated: March 1, 2013 BRUCE D. GOLDSTEIN, County Counsel By:_/s/ Anne L. Keck ANNE L. KECK Deputy County Counsel Attorneys for Defendant Sonoma County Sheriff Steve Freitas 18 19 20 21 22 Dated: March 1, 2013 LAW OFFICE OF RICHARD L. COSHNEAR By:_/s/ Richard L. Coshnear RICHARD L. COSHNEAR Attorney for Plaintiff 23 24 25 26 27 28 STIPULATION EXTENDING TIME FOR SONOMA COUNTY SHERIFF TO RESPOND TO COMPLAINT; PROPOSED ORDER 2 CV-13-0551 [PROPOSED] ORDER 1 2 Pursuant to the foregoing stipulation, and with good cause appearing, 3 IT IS HEREBY ORDERED that Defendant Sonoma County Sheriff Steve Freitas shall have 4 through and including March 21, 2013, to file a response to the Complaint. 5 03/12/2013 Dated: _________________ 8 NO 9 11 12 A H ER LI RT 10 onti amuel C Judge S FO 7 R NIA UNIT ED S T RT U O 6 ______________________________________ S DISTRICT TE UNITED STATES DISTRICT C COURT JUDGE A 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 STIPULATION EXTENDING TIME FOR SONOMA COUNTY SHERIFF TO RESPOND TO COMPLAINT; PROPOSED ORDER 3 CV-13-0551

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