Pakdel et al v. City and County of San Francisco et al

Filing 51

STIPULATION AND ORDER EXTENDING TIME TO FILE MOTION TO DISMISS, OPPOSITION TO MOTION TO DISMISS, AND REPLY TO OPPOSITION. Signed by Judge Richard Seeborg on 2/22/2022. (cl, COURT STAFF) (Filed on 2/22/2022)

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DAVID CHIU, State Bar #189542
City Attorney
KRISTEN A. JENSEN, State Bar #130196
CHRISTOPHER T. TOM, State Bar #271650
Deputy City Attorneys
City Hall, Room 234
San Francisco, California 94102-4682
Telephone: [phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
[e-mail]
Attorneys for Defendants
CITY AND COUNTY OF SAN FRANCISCO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
PEYMAN PAKDEL and SIMA CHEGINI,
Plaintiffs,
vs.
CITY AND COUNTY OF SAN FRANCISCO
a Chartered California City and County; SAN
FRANCISCO BOARD OF SUPERVISORS,
an elected body of the City and County of San
Francisco; SAN FRANCISCO
DEPARTMENT OF PUBLIC WORKS, a
department of the City and County of San
Francisco; and DOES 1-25 inclusive,

Case No. 3:17-cv-03638-RS
STIPULATION AND ORDER EXTENDING
TIME TO FILE MOTION TO DISMISS,
OPPOSITION TO MOTION TO DISMISS,
AND REPLY TO OPPOSITION
Trial Date:

N/A

Judge:

Richard Seeborg

Defendants.

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Pursuant to Local Rule 6-2, PEYMAN PAKDEL and SIMA CHEGINI (“Plaintiffs”) and City

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and County of San Francisco, a Chartered California City and County; San Francisco Board of

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Supervisors, an elected body of the City and County of San Francisco; and San Francisco Department

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of Public Works, a department of the City and County of San Francisco (collectively herein “San

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Francisco”) by and through their attorneys of record hereby stipulate and agree:

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Stipulation to Extend Filing Deadlines
Case No. 3:17-cv-03638-RS

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1.

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On November 29, 2021, the Court issued a Case Management Order establishing the

following briefing schedule for this matter:

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“Plaintiffs will file their First Amended Complaint on or before January 5, 2022[.]”

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“Defendant will file its motion to dismiss the First Amended Complaint on or before
March 2, 2022.”

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“Plaintiffs will file their response to the motion to dismiss on or before April 13, 2022.”

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“Defendant will file its reply on or before June 1, 2022.”

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2.

Plaintiffs filed their First Amended Complaint on January 5, 2022.

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3.

Due to unanticipated medical and health issues that caused San Francisco’s lead

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counsel Kristen Jensen to take sick leave as a result of contracting SARS-CoV-2, the parties agree that

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San Francisco may have an extension of time to file its motion to dismiss the First Amended

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Complaint from March 2, 2022 to April 1, 2022, or to other such date as is acceptable to the Court.
4.

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Plaintiffs may have an extension of time to file their opposition and response to the

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motion to dismiss from April 13, 2022 to May 13, 2022, or to other such date as is acceptable to the

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Court.

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5.

San Francisco may have an extension of time to file its reply to Plaintiffs’ opposition

and response from June 1, 2022 to July 1, 2022, or to other such date as is acceptable to the Court.
6.

The 30-day extensions agreed upon herein may extend the scheduling of other Court

dates and deadlines and that no party is prejudiced by these extensions.
IT IS SO STIPULATED.

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Dated: February 17, 2022

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DAVID CHIU
City Attorney
KRISTEN A. JENSEN
CHRISTOPHER T. TOM
Deputy City Attorneys
By: /s/ CHRISTOPHER T. TOM
CHRISTOPHER T. TOM

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Attorneys for Defendants
City and County of San Francisco, et al.

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Stipulation to Extend Filing Deadlines
Case No. 3:17-cv-03638-RS

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Dated: February 17, 2022

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JEFFREY W. McCOY
ROBERT H. THOMAS
JAMES S. BURLING
ERIN E. WILCOX
PAUL F. UTRECHT
THOMAS W. CONNORS

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By: /s/ JEFFREY W. McCOY (with consent)
JEFFREY W. McCOY

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Attorneys for Plaintiffs
Peyman Pakdel and Sima Chegini

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Stipulation to Extend Filing Deadlines
Case No. 3:17-cv-03638-RS

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[PROPOSED] ORDER
Pursuant to the foregoing stipulation of the parties, and good cause appearing therefore, IT IS
HEREBY ORDERED that:
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San Francisco may have an extension of time to file its motion to dismiss the First

Amended Complaint to April 1, 2022.
2.

Plaintiffs may have an extension of time to file their opposition and response to the

motion to dismiss to May 13, 2022.
3.

San Francisco may have an extension of time to file its reply to Plaintiffs’ opposition

and response to July 1, 2022.
IT IS SO ORDERED.
Dated: ______________, 2022
February 22

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_____________________________
Hon. Richard Seeborg
United States District Judge

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Stipulation to Extend Filing Deadlines
Case No. 3:17-cv-03638-RS

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