Filed: Jul. 22, 2015
Latest Update: Jul. 22, 2015
Summary: STIPULATION AND [PROPOSED] ORDER RE MOTION TO DISMISS JEFFREY S. WHITE , District Judge . Pro se plaintiff Sheila Blackman-Baham ("Plaintiff"), on behalf of herself, and Defendant Sally Jewell, Secretary, Department of Interior ("Defendant"), by and through her counsel, make the following representations and stipulate and agree as follows: 1. On April 29, 2015, Plaintiff filed her Complaint. See Docket No. 1. 2. On May 11, 2015, the U.S. Attorney's Office received a copy of Plaintiff
Summary: STIPULATION AND [PROPOSED] ORDER RE MOTION TO DISMISS JEFFREY S. WHITE , District Judge . Pro se plaintiff Sheila Blackman-Baham ("Plaintiff"), on behalf of herself, and Defendant Sally Jewell, Secretary, Department of Interior ("Defendant"), by and through her counsel, make the following representations and stipulate and agree as follows: 1. On April 29, 2015, Plaintiff filed her Complaint. See Docket No. 1. 2. On May 11, 2015, the U.S. Attorney's Office received a copy of Plaintiff'..
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STIPULATION AND [PROPOSED] ORDER RE MOTION TO DISMISS
JEFFREY S. WHITE, District Judge.
Pro se plaintiff Sheila Blackman-Baham ("Plaintiff"), on behalf of herself, and Defendant Sally Jewell, Secretary, Department of Interior ("Defendant"), by and through her counsel, make the following representations and stipulate and agree as follows:
1. On April 29, 2015, Plaintiff filed her Complaint. See Docket No. 1.
2. On May 11, 2015, the U.S. Attorney's Office received a copy of Plaintiff's Complaint by certified mail. See Declaration of Ann Marie Reding ("Reding Decl."), ¶ 2.
3. On July 10, 2015, Defendant filed a motion dismiss Plaintiff's complaint in its entirety. Defendant also filed an administrative motion to relate this case to an earlier-filed case involving the same parties and some of the same claims, Case No. CV 10-02656 JSW. Reding Decl., ¶ 3; Dkt No. 10 in Case No. CV 10-02656 JSW.
4. On July 16, 2015, Plaintiff wrote an email to counsel for Defendant requesting an extension of time to file her opposition to Defendant's motion to dismiss until August 21, 2015. Reding Decl. ¶ 4.
5. On July 20, 2015, the Court related this case to Case No. CV 10-02656 JSW, and reassigned this case to the Honorable Jeffrey S. White. The Court also vacated the hearing date on Defendant's motion to dismiss and requested that she re-notice the motion before Judge White. Id. ¶ 5.
6. On July 20, 2015, Defendant filed a re-notice of her motion to dismiss, noticing the hearing for September 25, 2015, at 9:00 a.m. before Judge White. Id. ¶ 6. On the same date, Plaintiff confirmed that she would still like the previously requested extension of time to file her opposition. Id.
7. In light of Plaintiff's request, the parties stipulate and agree to the following:
• August 21, 2015 — Last day for Plaintiff to file and serve her opposition to Defendant's motion to dismiss; and
• August 31, 2015 — Last day for Defendant to file and serve her reply in support of her motion to dismiss.
Id. at ¶ 7.
8. No prior extensions of time have been requested or granted. See id. at ¶ 8.
9. The requested time modifications will have no impact on the hearing on Defendant's motion to dismiss. See id.
[PROPOSED] ORDER
Plaintiff and Defendant's Stipulation and Proposed Order re Motion to Dismiss is hereby GRANTED. Plaintiff shall file her opposition to Defendant's motion to dismiss on or before August 21, 2015. Defendant shall file her reply on or before August 31, 2015. The hearing on Defendant's motion to dismiss is set for September 25, 2015 at 9:00 a.m.
