Ibarra v. City of Watsonville et al

Filing 21

Order Granting 17 Motion for Extension of Time to File Response/Reply re 16 MOTION to Dismiss DEFENDANTS NOTICE OF MOTION AND MOTION TO DISMISS PLAINTIFFS FIRST AMENDED COMPLAINT PURSUANT TO FRCP 12(b)(6) AND MOTION FOR A MORE DEFINITE STATEMENT PURSUANT TO FRCP 12(f). Response due 12/10/2012. Reply due 12/17/2012. Signed by Hon. Edward J. Davila on 11/14/2012.(ecg, COURT STAFF) (Filed on 11/14/2012)

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KATE WELLS (SBN 107051)
2600 Fresno Street
Santa Cruz, CA 95062
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
AARON LODGE (SBN 220670)
1414 Soquel Avenue, Suite 222
Santa Cruz, California 95062
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
Attorneys for plaintiff,
FRANCISCO IBARRA
Suzanne Solomon, Bar No. 169005
[e-mail]
LIEBERT CASSIDY WHITMORE
A Professional Law Corporation
153 Townsend Street, Suite 520
San Francisco, CA 94107
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
CITY OF WATSONVILLE

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION – ECF PROGRAM

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Kate Wells
and
Aaron
Lodge,
Attorneys
for plaintiff

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FRANCISCO IBARRA,

CASE # 5:12-cv-02271-EJD

Plaintiff,
v.
CITY OF WATSONVILLE, a municipal
corporation; CITY OF WATSONVILLE
POLICE DEPARTMENT; MANNY
SOLANO, individually and as Chief of
Police; TERENCE MEDINA, individually
and as former Chief of Police; BELCHER,
EHLE, MEDINA and ASSOCIATES;
TWENTY UNKNOWN CITY AND
OTHER EMPLOYEES,

STIPULATION TO ALLOW ADDITIONAL
TIME FOR PLAINTIFF TO RESPOND TO
DEFENDANT’S MOTION TO DISMISS,
SET FOR HEARING ON FEB. 8, 2013.
______________________

Defendants.

-1STIPULATION TO CHANGE RESPONSE DEADLINE

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WHEREAS, plaintiff’s lead counsel, Kate Wells, has been involved in a jury trial (Norse case)
during the past week, and up to the actual trial was completely immersed (as a solo attorney) in
preparations for that trial, and was therefore not able to work on a response to this motion, and
WHEREAS, plaintiff’s co-counsel, Aaron Lodge, has been involved in an extremely urgent
personal medical crisis involving his immediate family, and has been in doctor’s offices, medical
facilities and hospitals most of the past ten days, and
WHEREAS, Plaintiff’s attorney has contacted Defendant’s attorney, Suzanne Solomon, and both
sides are in agreement to extend the deadline, and
WHEREAS, an extension does not necessitate a change in the scheduled hearing date,
IT IS HEREBY STIPULATED that Plaintiff may respond to Defendant’s current motion by
December 10, 2012, with replies due one week later on December 17, 2012, and the hearing
remaining unchanged, on February 8, 2013.

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IT IS SO STIPULATED.
Dated:

Nov. 7, 2012

____________________/S/_________________________
AARON LODGE, Attorney for Plaintiff FRANK IBARRA

Dated:

Nov. 8, 2012

________________________________________________
SUZANNE SOLOMON, Attorney for Defendant
City of Watsonville

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PURSUANT TO STIPULATION, IT IS SO ORDERED, THAT:
Plaintiff must respond to the current motion by December 10, 2012. Replies shall be due by
December 17, 2012.

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Kate Wells
and
Aaron
Lodge,
Attorneys
for plaintiff

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November 14, 2012
Dated: ________________

__________________________
Edward J. Davila
United States District Judge

-2STIPULATION TO CHANGE RESPONSE DEADLINE