Hernandez v. Contra Costa

Filing 14

STIPULATION AND ORDER re 13 . STIPULATION WITH PROPOSED ORDER GRANTING LEAVE TO FILE FIRST AMENDED COMPLAINT AND EXTENDING DATE TO FILE RESPONSIVE PLEADINGS filed by Contra Costa, Felipe Hernandez. Signed by Magistrate Judge Kandis A. Westmore on 5/23/18. (sisS, COURT STAFF) (Filed on 5/23/2018)

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SHARON L. ANDERSON (SBN 94814)
County Counsel
DYLAN RADKE (SBN 207757)
Deputy County Counsel
COUNTY OF CONTRA COSTA
651 Pine Street, Ninth Floor
Martinez, California 94553
Telephone: [phone]
Facsimile: [phone]
Electronic Mail: [e-mail]
Attorneys for Defendant
COUNTY OF CONTRA COSTA
JOHN L. BURRIS, ESQ., SBN 69888
BEN NISENBAUM, ESQ., SBN 222173
JAMES COOK ESQ., SBN 300212
LAW OFFICES OF JOHN L. BURRIS
Airport Corporate Centre
7677 Oakport Street, Suite 1120
Oakland, California 94621
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff
FELIPE HERNANDEZ

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FELIPE HERNANDEZ, an individual,

. Case No.: 4:18-cv-00267-KAW

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Plaintiff,

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v.

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COUNTY OF CONTRA COSTA, a
municipal corporation; and DOES 1-50,

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STIPULATION AND [PROPOSED]
ORDER GRANTING LEAVE TO FILE
FIRST AMENDED COMPLAINT AND
EXTENDING DATE TO FILE
RESPONSIVE PLEADINGS

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Stipulation and [Proposed] Order Extending Date to File Responsive Pleadings –
Case No. 4:18-cv-00267-KAW
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inclusive,
Defendants.

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Crtrm: 4, 3rd Floor
Judge: Hon. Kandis A. Westmore, Presiding
Date Action Filed: January 11, 2018
Trial Date: None Assigned

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The parties, by and through their attorneys, have met and conferred regarding Plaintiff
Felipe Hernandez’s (“Plaintiff”) complaint and this Court’s order extending date to file
responsive pleadings and continuing case management conference and related dates. On
March 30, 2018, the Court ordered Plaintiff to file an amended complaint by April 17, 2018.
The Court also continued the case management conference to July 10, 2018. However,
Plaintiff needs more time to complete the amended complaint. Based on the parties’
conversation, the parties agreed that additional time is needed for Plaintiff to file an amended
complaint. Based on the above the parties have agreed to stipulate to the following time
schedule:
(1)

fourteen days after this Court grants the order to file it. The County’s

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responsive pleadings will be filed fourteen days after the amended complaint is

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filed.

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The parties stipulate that Plaintiff will file an amended complaint within

(2)

The parties stipulate that the case management conference remain scheduled for
July 10, 2018.

In light of the current procedural posture, the parties believe good cause exists to
provide time for Plaintiff file an amended complaint, to extend time for the County to file
responsive pleadings.
DATED: May 18,
2018

SHARON L. ANDERSON
COUNTY COUNSEL
By:/s/ Dylan Radke
DYLAN RADKE
Deputy County Counsel
Attorneys for Defendant
COUNTY OF CONTRA COSTA

Stipulation and [Proposed] Order Extending Date to File Responsive Pleadings –
Case No. 4:18-cv-00267-KAW
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DATED: May 18, 2018

JOHN L. BURRIS LAW OFFICES

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By:/s/ James Cook
JAMES COOK
Attorney for Plaintiff
FELIPE HERNANDEZ

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Stipulation and [Proposed] Order Extending Date to File Responsive Pleadings –
Case No. 4:18-cv-00267-KAW
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ORDER

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There is good cause to allow Plaintiff to file an amended complaint within fourteen

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days after this Court grants the order to file it. The County’s responsive pleadings will be

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filed fourteen days after the amended complaint is filed.

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There is further good cause to keep the case management conference on schedule for

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July 10, 2018 at 1:30 P.M. before the honorable Kandis A. Westmore. The joint case

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management statement is due July 3, 2018. All associated dates, including the date for the

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parties to exchange initial disclosures, are likewise continued.

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IT IS SO ORDERED.

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5/23/18
DATED:___________________

By:______________________________
HON. KANDIS A. WESTMORE
United States Magistrate Judge

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Stipulation and [Proposed] Order Extending Date to File Responsive Pleadings –
Case No. 4:18-cv-00267-KAW
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