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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1 2 3 4 5 6 7 8 9 10 11 Craig M. Peters SBN 184018 ALTAIR LAW 465 California Street, 5th Floor San Francisco, CA 94104-3313 (415) 988-9828 cpeters@altairlaw.us 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: (415) 781-3333 Fax: (415) 707-6600 joseph@josephmaylaw.com Attorneys for Plaintiff J.H., a Minor, through his Guardian ad Litem, Joan Tillman 12 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 13 14 15 16 J.H., a minor, through his Guardian ad Litem, JOAN TILLMAN, 17 18 19 20 21 22 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. 23 24 25 26 27 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 28 1 J.H. v. County of San Mateo, Case No. 20-CV-00961-VC STIPULATION TO CONTINUE CMC, 12(b)(6), AND DEADLINES 1 dismiss Plaintiff’s First Amended Complaint (ECF-33), is required to be filed by December 7, 2 2020. As such, Defendants’ responsive pleading to Plaintiff’s Second Amended Complaint is 3 due no later than January 11, 2021. 4 Plaintiff and Defendants further hereby stipulate to continue the initial Case Management 5 Conference currently set for October 20, 2020 at 10:00 a.m. to a date following Defendants’ 6 filing of their responsive pleading or after January 11, 2021 given that the case is not at issue and 7 it is unclear at this time how or to what extent Plaintiff may amend its complaint. Plaintiff and 8 Defendants have made repeated attempts to contact defendant Dawson’s counsel via email and 9 telephone but as of this date, Dawson’s counsel has not responded. Additionally, the court’s 10 reference during the October 8, 2020 hearing to the possibility of staying the civil case while the 11 underlying criminal case against defendant Dawson is pending further supports a continuance of 12 the initial Case Management Conference. 13 14 IT IS SO STIPULATED. 15 Dated: October 13, 2020 ALTAIR LAW and LAW OFFICE OF JOSEPH S. MAY 16 17 /s/ Joseph S. May By: JOSEPH S. MAY Attorneys for Plaintiff J.H. 18 19 20 21 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 22 23 24 25 26 /// 27 /// 28 /// 2 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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