Cornejo v. California Highway Patrol et al

Filing 34

STIPULATION AND ORDER extending time for briefing and hearing on defendants' Motion to Dismiss; or, in the alternative, for a More Definitive Statement. Signed by Judge Richard Seeborg on 11/23/16. (cl, COURT STAFF) (Filed on 11/23/2016)

1 GREGORY B. THOMAS, ESQ. (SBN 239870)
ADAM A. VUKOVIC, ESQ. (SBN 301392)
2 SOPHIA V. COHN, ESQ. (SBN 306661)
BOORNAZIAN, JENSEN & GARTHE
3 A Professional Corporation
555 12th Street, Suite 1800
4 Oakland, CA 94607
Telephone: [phone]
5 Facsimile: [phone]
[e-mail]
6 [e-mail]
[e-mail]
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Attorneys for Defendant
8 COUNTY OF ALAMEDA, sued herein as “ALAMEDA COUNTY SHERIFF’S OFFICE,”
KEVIN BEYRODT, AARON INNS, ANTHONEY FIELDS, IAN STEWART, KAREN
9 EASLING, sued herein as “K. EASLING,” and CAMERON TRACY
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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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14 YOLANDA FRAUSTO individually and as )
successor in interest to the Estate of Decedent )
15 John Anthony Cornejo,
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Plaintiffs,
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vs.
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CALIFORNIA HIGHWAY PATROL,
)
19 ALAMEDA COUNTY SHERIFF’S OFFICE, )
KEVIN BEYRODT, NORMAND D.
)
20 CORNEJO, II, and DOES 1 to 30, inclusive, )
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Defendants.
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22 And Related Actions
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Case No.: 3:16-cv-00974-RS
And Related Actions
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
BRIEFING AND HEARING ON
DEFENDANTS’ MOTION TO
DISMISS; OR, IN THE
ALTERNATIVE, FOR A MORE
DEFINTE STATEMENT PURSUANT
TO L.R. 6-1(a)

Pursuant to the United States District Court for the Northern District of California Civil

25 Local rule 6-1(a), the parties in the above-captioned matter hereby stipulate and agree to amend the
26 briefing and hearing schedule on Defendants COUNTY OF ALAMEDA, sued herein as
27 “ALAMEDA COUNTY SHERIFF’S OFFICE,” KEVIN BEYRODT, AARON INNS,
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-1STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR BRIEFING AND HEARING ON
DEFENDANTS’ MOTION TO DISMISS; OR, IN THE ALTERNATIVE, FOR A MORE DEFINTE STATEMENT
Norman Cornejo v. County of Alameda, et al. - Case No.: 3:16-cv-00947-RS; and related actions

1 ANTHONEY FIELDS, IAN STEWART, KAREN EASLING, sued herein as “K. EASLING,” and
2 CAMERON TRACY’s (hereinafter “Defendants”) Motion to Dismiss, or, in the alternative,
3 Motion for a More Definite Statement.
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WHEREAS Defendants filed a Motion to Dismiss, or, in the alternative, Motion for a More

5 Definite Statement on November 14, 2016, setting the matter for hearing on December 22, 2016.
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WHEREAS the Court set the following briefing schedule:

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Plaintiff’s Opposition due November 28, 2016;

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Defendants’ Reply to Opposition due December 5, 2016;

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Hearing on December 22, 2016.

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WHEREAS the parties, as a matter of professional courtesy, agree to extend the hearing on

11 this matter and all remaining briefing deadlines by one week.
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WHEREAS the parties hereby stipulate and agreed to the following briefing and hearing

13 schedule:
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Plaintiff’s Opposition due December 5, 2016;

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Defendants’ Reply to Opposition due December 12, 2016;

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Hearing on December 29, 2016.

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Respectfully submitted,

18 DATED: November 21, 2016
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BOORNAZIAN, JENSEN & GARTHE
A Professional Corporation

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By: ___/s/ Gregory B. Thomas
GREGORY B. THOMAS, ESQ.
ADAM A. VUKOVIC, ESQ.
SOPHIA V. COHN, ESQ.
Attorneys for Defendant
COUNTY OF ALAMEDA, sued
herein as “ALAMEDA COUNTY
SHERIFF’S OFFICE,” KEVIN
BEYRODT, AARON INNS,
ANTHONEY FIELDS, IAN
STEWART, KAREN EASLING,
sued herein as “K. EASLING,” and
CAMERON TRACY
-2STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR BRIEFING AND HEARING ON
DEFENDANTS’ MOTION TO DISMISS; OR, IN THE ALTERNATIVE, FOR A MORE DEFINTE STATEMENT
Norman Cornejo v. County of Alameda, et al. - Case No.: 3:16-cv-00947-RS; and related actions

1 DATED: November 21, 2016

LAW OFFICES OF NIKOLAUS W. REED

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By: __/s/ Nikolaus W. Reed_________
NIKOLAUS W. REED, ESQ.
Attorney for Plaintiff
NORMAN CORNEJO

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DATED: November 21, 2016

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QUIRK LAW GROUP, APC

By: __/s/ Logan Quirk________________
LOGAN QUIRK, ESQ.
Attorney for Plaintiff
NORMAN CORNEJO

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ATTESTATION

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I, Gregory B. Thomas, am counsel for Record for Defendants County of Alameda, et al. I am
the registered ECF user whose username and password are being used to file this stipulation. In
compliance with Local Rule 5-1(i)(3), I hereby attest that the above-identified counsel concurred in
this filing.
Dated: November 21, 2016

BOORNAZIAN, JENSEN & GARTHE
By: _/s/ Gregory B. Thomas_______________
GREGORY B. THOMAS
Attorney for Defendants
COUNTY OF ALAMEDA, sued herein
as “ALAMEDA COUNTY SHERIFF’S
OFFICE,” KEVIN BEYRODT,
AARON INNS, ANTHONEY FIELDS,
IAN STEWART, KAREN EASLING,
sued herein as “K. EASLING,” and
CAMERON TRACY

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-3STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR BRIEFING AND HEARING ON
DEFENDANTS’ MOTION TO DISMISS; OR, IN THE ALTERNATIVE, FOR A MORE DEFINTE STATEMENT
Norman Cornejo v. County of Alameda, et al. - Case No.: 3:16-cv-00947-RS; and related actions

1 PURSUANT TO STIPULATION, IT IS SO ORDERED.
2 DATED: __________, 2016
11/23
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_________________________________
HON. RICHARD SEEBORG
Judge of the United States District Court

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-4STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR BRIEFING AND HEARING ON
DEFENDANTS’ MOTION TO DISMISS; OR, IN THE ALTERNATIVE, FOR A MORE DEFINTE STATEMENT
Norman Cornejo v. County of Alameda, et al. - Case No.: 3:16-cv-00947-RS; and related actions