Filed: Oct. 29, 2014
Latest Update: Oct. 29, 2014
Summary: STIPULATED REQUEST AND [PROPOSED] ORDER FOR EXTENDING DEADLINE TO RESPOND TO DEFENDANT'S MOTION TO DISMISS EDWARD M. CHEN, District Judge. Pursuant to Civil Local Rules 6-2 and 7-12, IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys of record, that subject to the Court's approval, the deadline for Plaintiff's Opposition or Statement of Nonopposition to Defendant's Motion to Dismiss First Amended Complaint shall be extended to November 7, 2014, a
Summary: STIPULATED REQUEST AND [PROPOSED] ORDER FOR EXTENDING DEADLINE TO RESPOND TO DEFENDANT'S MOTION TO DISMISS EDWARD M. CHEN, District Judge. Pursuant to Civil Local Rules 6-2 and 7-12, IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys of record, that subject to the Court's approval, the deadline for Plaintiff's Opposition or Statement of Nonopposition to Defendant's Motion to Dismiss First Amended Complaint shall be extended to November 7, 2014, an..
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STIPULATED REQUEST AND [PROPOSED] ORDER FOR EXTENDING DEADLINE TO RESPOND TO DEFENDANT'S MOTION TO DISMISS
EDWARD M. CHEN, District Judge.
Pursuant to Civil Local Rules 6-2 and 7-12, IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys of record, that subject to the Court's approval, the deadline for Plaintiff's Opposition or Statement of Nonopposition to Defendant's Motion to Dismiss First Amended Complaint shall be extended to November 7, 2014, and Plaintiff's Reply shall be due by November 14, 2014 ("Stipulation"). This Stipulation is based on the following:
1. Defendant filed a Notice of Motion and Motion to Dismiss First Amended Complaint ("Motion") on October 14, 2014. Dkt. No. 56.
2. Plaintiff Steve Crump ("Plaintiff") is incarcerated at Richard J. Donovan Correctional Facility ("Richard J. Donovan") in San Diego, California. Officials at Richard J. Donovan have informed counsel for Plaintiff that Plaintiff is not permitted to make or receive telephone calls. Declaration of Rebecca A. Jacobs in Support of Stipulated Request and [Proposed] Order for Extending Deadline to Respond to Defendant's Motion to Dismiss ("Jacobs Decl.") at ¶3.
3. Plaintiff's counsel are located in San Francisco. Jacobs Decl. at ¶4. 4. Plaintiff's counsel have attempted to communicate with Plaintiff regarding the Opposition or Statement of Nonopposition to the Motion but have been unable to do so to date. Jacobs Decl. at ¶5.
5. The parties have not previously requested any extensions to Court-ordered deadlines. The proposed change will not affect any other deadlines or the trial date set by the Court. Jacobs Decl. at ¶6.
6. The Motion pertains to Plaintiff's Second Cause of Action, and the hearing date for the Motion is currently set for November 20, 2014. Dkt. No. 56.
7. Pursuant to the Court's Case Management and Pretrial Order for Jury Trial, the last day to the amend the pleadings is November 30, 2014. Dkt. No. 52.
8. The parties respectfully request that the Court enter an Order approving this Stipulation. In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that the concurrence in the filing of this document has been obtained from the other signatory hereto.
[PROPOSED] ORDER
Pursuant to stipulation, IT IS SO ORDERED.
