Myrah Martinez et al v. County of Sonoma et al

Filing 65

STIPULATION AND ORDER re 64 STIPULATION WITH PROPOSED ORDER re 61 MOTION to Strike 57 Answer to Amended Complaint, filed by Stacie Kabour, Sonoma County Family, Youth and Children's Services, Sonoma County Human Services Department, County of Sonoma, Jerry Dunn, Nick Honey. Signed by Judge Jon S. Tigar on February 17, 2016. (wsn, COURT STAFF) (Filed on 2/17/2016)

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Mark E. Merin (State Bar No. 043849)
Paul H. Masuhara (State Bar No. 289805)
LAW OFFICE OF MARK E. MERIN
1010 F Street, Suite 300
Sacramento, California 95814
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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Bonnie A. Freeman, Esq. (SB 180502)
SENNEFF FREEMAN & BLUESTONE, LLP
50 Old Courthouse Square, Suite 401
P.O. Box 3729
Santa Rosa, CA 95402-3729
Telephone:
707-526-4250
Facsimile:
707-526-0347
[e-mail]

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Attorneys for Defendants

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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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Case No. 3:15-cv-01953-JST

MYRAH MARTINEZ, et al.,

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Plaintiffs,

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vs.

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STIPULATION TO CONTINUE ASSOCIATED
DEADLINES ON PLAINTIFFS’ MOTION TO
STRIKE; [PROPOSED] ORDER

COUNTY OF SONOMA, et al.,

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Defendants.
WHEREAS, plaintiffs have filed an amended notice on plaintiffs’ motion to strike affirmative

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defenses from defendants’ joint answer which is currently scheduled for a hearing based upon the before

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the Court on March 31, 2016. See ECF No. 62.

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WHEREAS, defendants’ counsel Bonnie Freeman is currently on vacation and is unavailable to
meet the associated deadline to respond to said motion on February 23, 2016;
WHEREAS, the parties, through their representatives, have agreed to stipulate to continue the

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opposition and reply dates for said motion from the new hearing date based upon Ms. Freeman’s

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unavailability the parties hereby STIPULATE to the following:

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STIPULATION TO CONTINUE ASSOCIATED DEADLINES ON PLAINTIFFS’ MOTION TO STRIKE; [PROPOSED] ORDER
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST

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1.

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the Court's rescheduling of the associated deadline for defendants to respond to said
motion to be continued to March 8, 2016; and

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the Court's rescheduling of the associated deadline for plaintiffs to reply to said motion to
be continued to March 15, 2016.

Dated: February 17, 2016

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Respectfully Submitted,
LAW OFFICE OF MARK E. MERIN

BY:l~

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Ma-;k E. Merin
Attorneys for Plaintiffs
MYRAH MARTINEZ, KlTARA MCCRAY,
MADISON MARLENE MARVEL, STAR SMITH,
andR.M.

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Dated: February 17, 2016

Respectfully Submitted,
SENNEFF FREEMAN & BLUESTONE, LLP

/S/ Bonnie A. Freeman
By:

-------------------------------Bonnie A. Freeman
Attorneys for Defendants County of Sonoma (also sued as
Sonoma County Human Services Department and Sonoma
County Family, Youth and Children's Services), Jerry
Dunn, Nick Honey and Stacie Kabour

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STIPULATION TO CONTINUE ASSOCIATED DEADLINES ON PLAINTIFFS' MOTION TO STRIKE; [PROPOSED] ORDER
Martinez v. County o/Sonoma; United States District Court, Northern District of California, Case No. 3:l5-cv-OI953-JST

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[PROPOSED] ORDER

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Pursuant to the parties’ stipulation and finding good cause, the Court hereby ORDERS the

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following:
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the associated deadline for defendants to respond to said motion is continued to March 8,
2016; and

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the associated deadline for plaintiffs to reply to said motion is continued to March 15,

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2016.

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IT IS SO ORDERED.

S

R NIA

VED
APPRO
_________________________________________
JON S. TIGAR, DISTRICT JUDGE
UNITED STATES DISTRICT COURT

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UNIT
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Dated: February 17, 2016

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STIPULATION TO CONTINUE ASSOCIATED DEADLINES ON PLAINTIFFS’ MOTION TO STRIKE; [PROPOSED] ORDER
Martinez v. County of Sonoma; United States District Court, Northern District of California, Case No. 3:15-cv-01953-JST