J.H. v. County of San Mateo et al

Filing 37

ORDER by Judge Vince Chhabria granting 34 Stipulation to continue CMC and extend deadline to respond to second amended complaint; granting 36 Motion for Joinder in stipulation. (vclc2S, COURT STAFF) (Filed on 10/14/2020)

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Craig M. Peters SBN 184018
ALTAIR LAW
465 California Street, 5th Floor
San Francisco, CA 94104-3313
[phone]
[e-mail]
Joseph S. May SBN 245924
Has S. Jawandha SBN 322005
LAW OFFICE OF JOSEPH S. MAY
1388 Sutter Street, Suite 810
San Francisco, CA 94109
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff J.H., a Minor,
through his Guardian ad Litem, Joan Tillman

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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J.H., a minor, through his Guardian ad
Litem, JOAN TILLMAN,

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Plaintiff,
v.
COUNTY OF SAN MATEO; AYSE
DOGAN; JULIE BERKOVATZ;
TAMIKA DAWSON; and DOES 1 to 50,
inclusive,

CASE NO. 20-CV-00961-VC

STIPULATION TO CONTINUE CASE
MANAGEMENT CONFERENCE AND
EXTEND THE DEADLINE FOR
DEFENDANTS TO FILE THEIR
RESPONSE TO PLAINTIFF’S SECOND
AMENDED COMPLAINT
Action Filed: February 7, 2020
Trial Date:
TBD

Defendants.

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Plaintiff J.H. (“Plaintiff”) and Defendants COUNTY OF SAN MATEO, AYSE DOGAN,
and JULIE BERKOVATZ (“Defendants”) hereby stipulate, by and through their counsel, to
extend the deadline by two weeks for Defendants to file their responsive pleading to Plaintiff’s
Second Amended Complaint which, following the court’s ruling on Defendants’ motion to

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J.H. v. County of San Mateo, Case No. 20-CV-00961-VC
STIPULATION TO CONTINUE CMC, 12(b)(6), AND DEADLINES

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dismiss Plaintiff’s First Amended Complaint (ECF-33), is required to be filed by December 7,

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2020. As such, Defendants’ responsive pleading to Plaintiff’s Second Amended Complaint is

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due no later than January 11, 2021.

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Plaintiff and Defendants further hereby stipulate to continue the initial Case Management

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Conference currently set for October 20, 2020 at 10:00 a.m. to a date following Defendants’

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filing of their responsive pleading or after January 11, 2021 given that the case is not at issue and

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it is unclear at this time how or to what extent Plaintiff may amend its complaint. Plaintiff and

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Defendants have made repeated attempts to contact defendant Dawson’s counsel via email and

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telephone but as of this date, Dawson’s counsel has not responded. Additionally, the court’s

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reference during the October 8, 2020 hearing to the possibility of staying the civil case while the

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underlying criminal case against defendant Dawson is pending further supports a continuance of

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the initial Case Management Conference.

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IT IS SO STIPULATED.

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Dated: October 13, 2020

ALTAIR LAW
and
LAW OFFICE OF JOSEPH S. MAY

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/s/ Joseph S. May
By: JOSEPH S. MAY
Attorneys for Plaintiff J.H.

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Dated: October 13, 2020

JOHN C. BEIERS, COUNTY COUNSEL
/s/ Joseph F. Charles__________________
By: JOSEPH F. CHARLES and
KIMBERLY A. MARLOW
Attorneys for Defendants County of San
Mateo, Dogan, and Berkovatz

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J.H. v. County of San Mateo, Case No. 20-CV-00961-VC
STIPULATION TO CONTINUE CMC, 12(b)(6), AND DEADLINES