Marlowe v. City and County of San Francisco et al

Filing 45

ORDER APPROVING STIPULATION TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS' MOTION TO DISMISS. Plaintiff's new deadline to respond to defendants' motion to dismiss is December 22, 2016. Signed by Judge Maxine M. Chesney on 12/21/16. (mmclc2, COURT STAFF) (Filed on 12/21/2016)

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ALEXANDER S. ZALKIN, ESQ. (#280813)
The Zalkin Law Firm, P.C.
12555 High Bluff Drive, Suite 301
San Diego, CA 92130
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorney for Plaintiff

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DENNIS J. HERRERA (#139669)
City Attorney
CHERYL ADAMS (#164194)
Chief Trial Deputy
MARGARET W. BAUMGARTNER (#151762)
RENEE L. ERICKSON (#304983)
Deputy City Attorneys
1390 Market Street, 6th
Tel: [phone]
Fax: [phone]
Email: [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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HEATHER MARLOWE, an individual,
Plaintiff,

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vs.
CITY AND COUNTY OF SAN
FRANCISCO, a governmental entity;
SUZY LOFTUS, individually and in her
official capacity as President of the San
Francisco Police Commission; GREG
SURH, individually and in his official
capacity as Chief of Police of the San
Francisco Police Department; MIKAIL
ALI, individually and in his official
capacity of Deputy Chief of the San
Francisco Police Department; JOE
CORDES, individually and in his official
capacity as an officer of the San Francisco
Police Department; and Does 6 through
100, inclusive,
Defendants.

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Case No.: 3:16-cv-00076-MMC
STIPULATION TO EXTEND
DEADLINE TO RESPOND TO
DEFENDANTS’ MOTION TO DISMISS
AND [PROPOSED] ORDER

Dept:
Judge:

Courtroom 7, 19th floor
Maxine M. Chesney

Date of Filing: December 21, 2016

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3:16-cv-00076 -MMC

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STIPULATION TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS’
MOTION TO DISMISS AND [PROPOSED] ORDER

WHEREAS, Plaintiff filed her Second Amended Complaint (“SAC”) on October 21,

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2016;
WHEREAS, Defendants filed their Rule 12(b)(6) Motion to Dismiss Plaintiff’s SAC
(“Motion”) on November 23, 2016;
WHEREAS, based on Defendants’ counsel’s request, the Parties agreed, and this Court
ordered, that Plaintiff’s deadline to respond to Defendants’ Motion be moved to December 21,

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2016 and Defendants’ deadline to reply be moved to December 30, 2016;
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WHEREAS, an unexpected personal issue precluded Plaintiff’s from working on
Plaintiff’s Response to Defendant’s Motion on December 20, 2016;
WHEREAS, the Parties have agreed to allow Plaintiff a one day extension to respond,
making Plaintiff’s new deadline December 22, 2016;
WHEREAS, this one-day extension will have no effect on Defendant’s deadline to
Reply to Plaintiff’s response, or on the hearing date on Defendant’s Motion;

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3:16-cv-00076 -MMC

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STIPULATION TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS’
MOTION TO DISMISS AND [PROPOSED] ORDER

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NOW THEREFORE, the Parties hereby stipulate, and request that this Court order, that

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the deadline for Plaintiff to respond to Defendants’ Motion be extended from December 21,

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2016 to December 22, 2016.

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Date: December 21, 2016

THE ZALKIN LAW FIRM, P.C

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By:

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Date: December 21, 2016

/s/ Alexander S. Zalkin
Alexander S. Zalkin
Attorney for Plaintiff
HEATHER MARLOWE

DENNIS J. HERRERA
City Attorney
CHERYL ADAMS
Chief Trial Deputy
MARGARET W. BAUMGARTNER
RENEE L. ERICKSON
Deputy City Attorneys

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By:
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/s/ Renne L. Erickson___
Renee L. Erickson
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO

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ATTESTATION CLAUSE
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I attest under penalty of perjury that concurrence in the filing of this document has been
obtained from the above signatories.

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Date: December 21, 2016

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By: /s/ Alexander S. Zalkin
Alexander S. Zalkin
Attorney for Plaintiff
HEATHER MARLOWE

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3:16-cv-00076 -MMC

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STIPULATION TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS’
MOTION TO DISMISS AND [PROPOSED] ORDER

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PROPOSED ORDER

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IT IS HEREBY ORDERED, that Plaintiff’s new deadline to respond to Defendants’
Rule 12(b)(6) Motion to Dismiss Plaintiff’s Second Amended Complaint is December 22, 2016.

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December 21, 2016
Dated: ______

By:_______________________________
United States District Judge

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3:16-cv-00076 -MMC

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STIPULATION TO EXTEND DEADLINE TO RESPOND TO DEFENDANTS’
MOTION TO DISMISS AND [PROPOSED] ORDER