Green et al v. Betz

Filing 26

STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT; ORDER. Signed by Judge Maxine M. Chesney on October 25, 2013. (mmclc2, COURT STAFF) (Filed on 10/25/2013)

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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]
Email: [e-mail]
Attorneys for Defendant
R. BETZ

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JOHN L. BURRIS, State Bar No. 69888
DEWITT M. LACY, State Bar No. 258789
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorneys for Plaintiffs
MARCELLUS GREEN; JENNIVIE GREEN;
JENNIVIE GREEN Guardian ad litem for C.G.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MARCELLUS GREEN; JENNIVIE GREEN;
JENNIVIE GREEN Guardian ad litem for C.G.;

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Case No. 3:13-cv-01671-MMC

Plaintiffs,

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

v.

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DEPUTY R. BETZ, individually and in his
capacity as a Deputy Sheriff for the
COUNTY OF ALAMEDA; DOES 1-10,
inclusive; individually and in their capacities
as DEPUTY SHERIFFS for COUNTY OF
ALAMEDA,

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Defendants.
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STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT
Green, et al. v. Betz, et al.
U.S.D.C. Northern District of CA Case No. 3:13-cv-01671-MMC

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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 April 12, 2013, Plaintiff filed the Complaint initiating the above-captioned action

against the County of Alameda and Deputy R. Betz.
2.

On October 11, 2013, plaintiff filed a second amended complaint in this action. The

response to that complaint is due October 25, 2013.
3.

Counsel for defendant will be out of the country on vacation from October 18 through

October 30, 2013.
4.

The parties therefore stipulate to extend the time for defendant to respond to the Second

Complaint through and including November 8, 2013.
5.

This extension will not alter any event or deadline already fixed by Court order.

DATED: October 25, 2013

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LAW OFFICES OF JOHN L. BURRIS
By: /s/ Dewitt Lacy
John L. Burris
DeWitt Lacy
Attorneys for Plaintiff
MARCELLUS GREEN, JENNIVIE GREEN,
JENNIVIE GREEN guardian ad litem for C.G.

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Dated: October 25, 2013

By: /s/ Michael C. Wenzel
Michael C. Wenzel
Attorneys for Defendants
and R. BETZ

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BERTRAND, FOX & ELLIOT

[PROPOSED] ORDER
Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the time for
Defendant to respond to plaintiff’s Second Amended Complaint shall be extended to November 8, 2013.

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October 25
Dated: _____________, 2013
Honorable Maxine M. Chesney
UNITED STATES SENIOR DISTRICT JUDGE

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2

STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO SECOND AMENDED COMPLAINT
Green, et al. v. Betz, et al.
U.S.D.C. Northern District of CA Case No. 3:13-cv-01671-MMC