Jodie White, et al v. United States of America, et al

Filing 32

STIPULATION AND ORDER re 31 STIPULATION WITH PROPOSED ORDER Changing Time for Plaintiffs to File an Amended Complaint and Federal Defendants to File a Responsive Pleadings filed by Jodie White, J. W., Lisa White. Signed by Judge Jon S. Tigar on July 6, 2015. (wsn, COURT STAFF) (Filed on 7/6/2015)

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RYAN T. DUNN (SBN: 215383)
MATTHEW R. CODY (SBN: 267191)
DUNN & PANAGOTACOS LLP
369 Pine Street, Suite 506
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiffs
JODIE WHITE, an individual, LISA WHITE, an individual, J.W., a minor by and through his
guardian ad litem LISA WHITE

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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JODIE WHITE, an individual, LISA WHITE,
an individual, J.W., a minor by and through his
guardian ad litem LISA WHITE

UNITED STATES OF AMERICA, SOCIAL
SECURITY ADMINISTRATION, RYAN
LUIS, and DOES 1-20, inclusive,

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Defendants.
g

Dunn & Panagotacos LLP
369 Pine Street, Suite 506
San Francisco, CA 94104

vs.

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STIPULATED REQUEST FOR ORDER
CHANGING TIME FOR PLAINTIFFS TO
FILE AN AMENDED COMPLAINT AND
FEDERAL DEFENDANTS TO FILE A
RESPONSIVE PLEADING; [PROPOSED]
ORDER

Plaintiffs,

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Case No. C14-05604 JST

Plaintiffs Lisa White, Jodie White, and J.W., a minor by and through his guardian ad
litem Lisa White (collectively, “plaintiffs”), and defendants United States of America, Social

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Security Administration, and Ryan Luis (collectively, “federal defendants”), by and through their

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undersigned counsel, hereby stipulate and agree as follows:

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1. The Court’s June 24, 2015 Order Granting Defendants’ Motion to Dismiss provided

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plaintiffs until July 8, 2015 to file an amended complaint. See ECF No. 30. In the event
plaintiffs file an amended complaint, federal defendants’ response will be due 14 days after
the amended complaint is filed. See Fed. R. Civ. P. 15(a)(3).

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STIPULATED REQUEST FOR ORDER CHANGING TIME

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2. Subject to the approval of the Court, the parties hereby stipulate and agree to extend the

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deadline for plaintiffs’ to file an amended complaint and the deadline for federal defendants’

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to respond to an amended complaint as follows:

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Plaintiffs’ Deadline to File Amended Complaint: July 22, 2015
Federal Defendants’ Deadline to Respond to Amended Complaint: August 10, 2015
3. Plaintiffs’ counsel has informed federal defendants that plaintiff Lisa White has been the

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main contact for plaintiffs’ counsel in this action, and that plaintiffs’ counsel has been unable

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to confer with Ms. White about an amended complaint because she has been on vacation.

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Due to this difficulty, plaintiffs seek a two-week extension of the deadline for plaintiffs to

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file an amended complaint in this action, from July 8, 2015 until July 22, 2015. Federal

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defendants have agreed to this extension. Because federal defendants’ counsel anticipates

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that she will be out of the office for a portion of the last two weeks of July, the parties have

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agreed that federal defendants will have until August 10, 2015 to respond to an amended

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complaint.

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4. The Court has previously issued three orders continuing the initial case management in this

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action. Currently, the initial case management conference in this action is set for August 19,

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2015. The parties previously stipulated, pursuant to Local Rule 6-1(a), to extend the federal

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defendants’ deadline to respond to the Complaint by approximately two and half weeks.

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There have been no other time modifications in this action.
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Dated: July 1, 2015

DUNN & PANAGOTACOS LLP

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By: /s/
Matthew R. Cody
Attorneys for Plaintiffs

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STIPULATED REQUEST FOR ORDER CHANGING TIME

July 6, 2015