Olsen et al v. United States

Filing 16

Stipulation and Order to Extend Deadline for Defendant United States of America to Respond to the Complaint and to Continue the Initial Case Management Conference. The deadline for Defendant United States of America to Respond to the complaint sha ll be extended until and including 4/15/2015. Case Management Statement due by 4/24/2015. Initial Case Management Conference set for 5/1/2015 02:30 PM in Courtroom 10, 19th Floor, San Francisco. Signed by Judge Susan Illston on 3/9/15. (cl, COURT STAFF) (Filed on 3/9/2015)

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MELINDA HAAG (CABN 132612)
United States Attorney
ALEX G. TSE (CABN 152348)
Chief, Civil Division
MARK R. CONRAD (CABN 255667)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendant
Clayeo C. Arnold (SBN 65070)
Anthony M. Ontiveros (SBN 152758)
Kiersta D. Perlee (SBN 187675)
CLAYEO C. ARNOLD
A PROFESSIONAL LAW CORPORATION
865 Howe Avenue
Sacramento, CA 95825
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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SAMARN OLSEN and
NEOLANI OLSEN-RODRIGUEZ,

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Plaintiffs,
v.
UNITED STATES OF AMERICA,
Defendant.

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STIP TO CONT. CMC AND RESPONSE DEADLINE
Case No. C 14-05601 SI

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CASE NO. C 14-05601 SI
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
DEFENDANT UNITED STATES OF
AMERICA TO RESPOND TO THE
COMPLAINT AND TO CONTINUE
INITIAL CASE MANAGEMENT
CONFERENCE

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WHEREAS, Plaintiffs Samarn Olsen and Neolani Olsen-Rodriguez filed the above-captioned

2 action on December 23, 2014, see Dkt. Nos. 1 & 2;
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WHEREAS, Plaintiffs have served a copy of the Complaint for Wrongful Death on the

4 Department of Justice in Washington, D.C., and the United States Attorney’s Office for the Northern
5 District of California in San Francisco, California;
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WHEREAS, Defendant United States of America, which is specially appearing in connection

7 with the matters addressed by this stipulation, asserts that service upon the United States has not been
8 completed as required under Federal Rule of Civil Procedure 4(i);
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WHEREAS, undersigned counsel for Defendant United States of America has a scheduling

10 conflict with the Initial Case Management Conference that was automatically set by the Court in this
11 matter for March 27, 2015;
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WHEREAS, to avoid litigation over the adequacy of service upon the United States, and to

13 accommodate the schedules of undersigned counsel for Defendant United States of America;
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NOW, THEREFORE, by and through their undersigned counsel in this action, the parties hereby

15 stipulate and agree as follows:
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The deadline for Defendant United States of America to respond to the Complaint shall be

17 extended until and including April 15, 2015. The Initial Case Management Conference set in this matter
18 shall be continued until Friday, May 1, 2015, at 2:30 p.m. Pursuant to the Standing Order for All Judges
19 of the Northern District of California dated August 25, 2014, the parties shall file a Joint Case
20 Management Statement not later than Friday, April 24, 2015.
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Respectfully submitted,

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MELINDA HAAG
United States Attorney

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/s/ Mark R. Conrad
MARK R. CONRAD
Assistant United States Attorney

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Case No. C 14-05601 SI

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1 DATED: March 5, 2015
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CLAYEO C. ARNOLD
A Professional Law Corporation

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/s/ Anthony M. Ontiveros
ANTHONY M. ONTIVEROS
Attorney for Plaintiffs

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7 IT IS SO ORDERED.
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Date: ________________________
3/9/2015

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_________________________________________
HON. SUSAN ILLSTON
United States District Court Judge

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STIP TO CONT. CMC AND RESPONSE DEADLINE
Case No. C 14-05601 SI

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