Marlene Henderson et al v. County of Santa Cruz et al

Filing 113

ORDER TO CONTINUE DEADLINE TO OPPOSE DEFENDANTS' 101 MOTION FOR SUMMARY JUDGMENT AND TO AUGMENT THE BRIEFING SCHEDULE granting 112 STIPULATION. Response due by 7/10/2020. Reply due by 7/17/2020. Motion Hearing set for 8/19/2020 02:00 PM in San Francisco, Courtroom 02, 17th Floor before Judge William H. Orrick. Signed by Judge William H. Orrick on 06/25/2020. (jmdS, COURT STAFF) (Filed on 6/25/2020)

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Michael J. Curls (SBN 159651)
Nichelle D. Jones (SBN 186308)
LAW OFFICE OF MICHAEL J. CURLS
4340 Leimert Boulevard, Suite 200
Los Angeles, California 90008
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
[e-mail]

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Attorneys for Plaintiff
Jody Struck, SBN 121097
HAAPALA, THOMPSON & ABERN, LLP
1939 Harrison Street, Suite 800
Oakland, California 94612
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
COUNTY OF SANTA CRUZ

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO

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MARLENE HENDERSON, THE ESTATE OF
EDYTH HENDERSON, and THE ESTATE
OF JOSEPH HENDERSON,
Plaintiffs,

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vs.
COUNTY OF SANTA CRUZ, THE SANTA
CRUZ COUNTY SHERIFF’S
DEPARTMENT, THE SANTA CRUZ
COUNTY HEALTH SERVICES AGENCY,
and DOES 1 THROUGH 25, INCLUSIVE,
Defendants

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Case No.: 3:14-cv-03544 WHO
(HRL)
STIPULATION AND ORDER TO
CONTINUE DEADLINE TO
OPPOSE DEFENDANTS’
MOTION FOR SUMMARY
JUDGMENT AND TO AUGMENT
THE BRIEFING SCHEDULE

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STIPULATION AND ORDER TO AMEND SCHEDULING ORDER (3:14CV-03544-WHO-HRL)

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TO THE HONORABLE COURT:

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This stipulation is entered into by and between the plaintiffs and the defendants,

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by and through their respective counsel.

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1.

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[Doc.101] Plaintiff’s response is due on or before March 4, 2020.
2.

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On February 19, 2020, Defendant filed a Motion for Summary Judgment.

On March 20, 2020, the scheduling order was augmented [Doc.107] and

the hearing was continued to July 17, 2020; Plaintiffs’ Opposition is due on June 26,
2020 and Defendant’s Reply is due on July 3, 2020.

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3.

Since the COVID-19 quarantine, counsel for Plaintiff has experienced

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deaths of family and friends. As such, counsel have met and conferred and stipulated

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to a short continuance to allows Plaintiff’s counsel to deal with personal issues and

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additional time to file Plaintiff’s opposition.

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4.

The parties continue to engage in meaningful settlement dialogue.

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5.

Based on the foregoing, the parties seek to to extend the time for Plaintiff to

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respond to Defendants’ Motion for Summary Judgment from June 26, 2020 to July 10,

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2020; and the time for Defendant to file their Reply Brief from July 3, 2020 to July 17,

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2020.

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STIPULATION AND PROPOSED ORDER TO AMEND SCHEDULING ORDER
(3:14-CV-03544-WHO-HRL)

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6.

The parties further seek to amend the current scheduling order to continue

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the deadline to hear Motions for Summary Judgment from July 17, 2020 to July 31,

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2020 and to continue the hearing on Defendants’ Motion for Summary Judgment

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accordingly.

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NOW THEREFORE, IT IS HEREBY STIPULATED by the Parties, subject to
approval by this Court, that the Scheduling Order be amended as follows:

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Dated: June 25, 2020

LAW OFFICES OF MICHAEL J. CURLS

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By:

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*/s/ Nichelle D. Jones
Nichelle D. Jones
Attorney For Plaintiff

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Dated: June 25, 2020

HAAPALA, THOMPSON & ABERN, LLP
By:

/s/ Jody Struck
Jody Struck
Attorneys for Defendant
*Ms. Struck provided her consent that this
document be electronically filed

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STIPULATION AND PROPOSED ORDER TO AMEND SCHEDULING ORDER
(3:14-CV-03544-WHO-HRL)

MODIFIED ORDER

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PER STIPULATION OF COUNSEL, as modified below, IT IS HEREBY
ORDERED that the motion deadlines be revised as follows:
Deadline for Plaintiff to Respond
to Defendants’ Motion for Summary

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Judgment:

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Deadline for Defendants to Reply to

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Plaintiff’s Opposition to Motion for Summary

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July 10, 2020

Judgment:

July 17, 2020

Hearing on Defendants’ Motion for
Summary Judgment:

August 19, 2020

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DATED: June 25, 2020

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___________________
Judge of the United States District Court

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STIPULATION AND PROPOSED ORDER TO AMEND SCHEDULING ORDER
(3:14-CV-03544-WHO-HRL)