MOTION PURSUANT TO LOCAL RULE 6.1 REQUESTING A FURTHER EXTENSION OF TIME FOR DEFENDANT J. ABRAO TO FILE AN ANSWER; DECLARATION OF ALISON BERRY WILKINSON IN SUPPORT; and (PROPOSED) ORDER

WILLIAM ALSUP, District Judge.

Pursuant to Local Rule 6.1(b), Defendant DEPUTY J. ABRAO hereby submits this application to extend time for him to answer or otherwise respond to the Amended Complaint. This application is necessary in order to provide sufficient time for his newly substituted attorney to evaluate the action before submitting any responsive pleading.

On June 24, 2015, counsel for Defendant COUNTY OF SONOMA and all individual defendants requested jointly that this Court approve an order extending time for all Defendants to answer the Amended Complaint (ECF Docket No. 12). On June 29, 2015 this Court granted all defendants up to and including July 17, 2015 to file an answer to the amended complaint (ECF Docket No. 13). Subsequent to the issuance of the the order extending time (ECF Docket No. 13) Defendant COUNTY OF SOMONA determined that Defendant DEPUTY J. ABRAO should be represented by independent counsel, necessitating this motion to extend time in order to ensure that newly substituted counsel has an adequate opportunity to fully evaluate the case prior to filing a responsive pleading on behalf of Defendant J. ABRAO.

DECLARATION OF ALISON BERRY WILKINSON IN SUPPORT OF MOTION

I, Alison Berry Wilkinson, declare as follows:

1. I am an attorney at law licensed to practice before all courts in the State of California. I make this declaration based on my personal knowledge and, if called to testify, could and would testify competently to the matters contained herein.

2. It was determined by Defendant COUNTY OF SONOMA that Defendant DEPUTY J. ABRAO should have separate independent counsel in this matter. Steps were thereafter taken to obtain approval of my appointment as independent counsel.

3. Last week, I contacted counsel for Plaintiff CHARMAINE GRAY and advised her that this office would be filing a substitution of attorneys on behalf of Defendant DEPUTY J. ABRAO. I further sought her agreement to extend time for the filing of a responsive pleading from the scheduled date of July 17, 2015.

4. Plaintiff's counsel was on vacation at the time of my inquiry, and indicated by email that she was agreeable to a reasonable extension of time given the substitution of attorneys. Unfortunately, due to her being on vacation, a stipulation and proposed order was attempted, but not completed. Rather than wait for her return, which would only further delay the filing of a responsive pleading, I make this Motion.

5. In order to fully and adequately represent the interests of my new client, due diligence requires that I investigate and evaluate the underlying facts and pleadings developed to date before filing a responsive pleadings. I believe that I can accomplish those necessary tasks efficiently and expeditiously, and so therefore only seek an additional two week extension of time, up to and including August 7, 2015 for the filing of an Answer or other responsive pleading.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 20th day of July 2015, in San Rafael, California.

ORDER

Good cause having been shown, Defendant DEPUTY J. ABRAO shall have up to and including August 7, 2015 to file an answer to the amended complaint. All other dates remain as scheduled.

IT IS SO ORDERED.