Luong et al v. Alameda County et al

Filing 36

STIPULATION AND ORDER re 35 First MOTION to Dismiss Complaint re Briefing Schedule filed by Ai Qiong Zhong, Dat Thanh Luong, Mai Chai, W.L.. Responses due by 3/22/2018. Replies due by 4/5/2018. Motion Hearing set for 4/26/2018 01:30 PM in San Francisco, Courtroom 05, 17th Floor before Judge Edward M. Chen. Signed by Judge Edward M. Chen on 2/14/18. (bpf, COURT STAFF) (Filed on 2/14/2018)

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MICHAEL J. HADDAD (State Bar No. 189114)
JULIA SHERWIN (State Bar No. 189268)
MAYA SORENSEN (State Bar No. 250722)
TERESA ALLEN (State Bar No. 264865)
HADDAD & SHERWIN LLP
505 Seventeenth Street
Oakland, California 94612
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
W.L., AI QIONG ZHONG, and MAI CHAI

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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W.L., AI QIONG ZHONG, and MAI CHAI,
individually,

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Plaintiff,
vs.
NAPA STATE HOSPITAL, CALIFORNIA
DEPARTMENT OF STATE HOSPITALS, a public
entity; PAM AHLIN; ALAMEDA COUNTY, a public
entity; UNDERSHERIFF RICHARD LUCIA; and
DOES 1-10, Jointly and Severally,
Defendants.

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No: 3:17-cv-06675-EMC
STIPULATION AND
PROPOSED ORDER TO
MODIFY BRIEFING
SCHEDULE FOR STATE
DEFENDANTS’ MOTION TO
DISMISS

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No. : 3:17-cv-06675-EMC STIP & PROPOSED ORDER TO MODIFY BRIEFING SCHEDULE

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STIPULATION
The parties, by and through their respective attorneys of record, hereby stipulate and agree
as follows:

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1.

On February 8, 2018, Defendants filed a Motion to Dismiss.

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2.

The parties jointly request that the Court continue the briefing schedule as follows:

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a) Plaintiff's Opposition will be due on or before March 22, 2018.

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b) Defendant's Reply will be due on or before April 5, 2018.
3.

Good cause exists because Plaintiffs have several major deadlines and

responsibilities in other pending cases, including filing an opposition to summary judgment in a
wrongful death case due in approximately three weeks and expert depositions in a separate

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wrongful death case that would make it impossible to adequately brief opposition papers to

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Defendants' motion by the current deadline of February 22, 2018.

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4.

For these reasons, the parties stipulate and request that this Court enter the following

order adjusting the briefing schedule for this motions.

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
Dated: February 13, 2018

HADDAD & SHERWIN LLP
/s/ Maya Sorensen
MAYA SORENSEN
Attorneys for Plaintiffs

Dated: February 13, 2018

ATTORNEY GENERAL OF CALIFORNIA
/s/ Jennifer Addams*
Attorneys for Defendants

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* Ms. Addams gave permission to use his electronic signature

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No. 3:17-cv-06675-EMC STIP & PROPOSED ORDER TO MODIFY BRIEFING SCHEDULE

ORDER

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PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS SO

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ORDERED. Plaintiff's Opposition to Defendants’ motion to dismiss is due no later than March 22,

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2018, and Defendants' reply is due no later than April 5, 2018.

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_______________________________
Hon. Edward Chen RDERED
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UNITED T IS SO DISTRICT COURT
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2/14/18
Dated: _______________

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No. 3:17-cv-06675-EMC STIP & PROPOSED ORDER TO MODIFY BRIEFING SCHEDULE

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