STIPULATION TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT AND TO CONTINUE INITIAL CASE MANAGEMENT AND RELATED DATES; PROPOSED ORDER

KANDIS A. WESTMORE, Magistrate Judge.

Pursuant to Civil Local Rule 7-12, all parties stipulate by and through their respective counsel, stipulate to extend the time for Defendant Alameda County to respond to Plaintiff's First Amended Complaint and to continue the initial case management conference scheduled for March 6, 2018 and related dates, including ADR deadlines, currently scheduled for February 13, 2018, and the last date to file a Rule 26(f) report, currently scheduled for February 27, 2018.

1. Plaintiff filed her Complaint on December 5, 2017 and her First Amended Complaint against Alameda County, Sheriff Gregory J. Ahern and other individual members of the Alameda County Sheriff's Office ("Alameda County Defendants"), the City of Oakland and individual Oakland Police Department officers ("City of Oakland Defendants").

2. As to the Alameda County Defendants, Plaintiff alleges various constitutional violations arising from her confinement at Santa Rita Jail in Dublin, California.

3. Alameda County was served on February 5, 2018, making February 26, 2018 the deadline for Alameda County to answer or otherwise respond to the First Amended Complaint. To date, no individual member of the Alameda County Sheriff's Office has been served, although defense counsel is working assiduously to obtain individual waivers of service from each individual member of the Alameda County Sheriff's Office.

4. Defense counsel just received this assignment on February 13, 2018 and immediately began evaluating the First Amended Complaint to prepare a response on behalf of the County of Alameda and to obtain waivers of service for the individually named Alameda County defendants.

5. The County of Alameda needs additional time to answer or otherwise respond to the First Amended Complaint. The individually named Alameda County defendants have not yet been served, but defense counsel anticipates that waivers of service of process will be obtained.

6. The parties have met and conferred and agree to extend the time for the County of Alameda to answer or otherwise respond to Plaintiff's First Amended Complaint by 60 days, from the current deadline of February 26, 2018 to April 27, 2018.

7. By order dated December 6, 2018, the Court set an initial case management conference on March 6, 2018. Dkt. No. 4. The parties further stipulate to continue the initial case management conference currently scheduled for March 6, 2018 to May 4, 2018 and all related dates by sixty days.

8. No prior extensions of time have been requested by the County of Alameda.

THEREFORE, IT IS HEREBY STIPLUATED by and between Plaintiff and Defendants that Defendants will have until April 27, 2018 to respond to Plaintiff's First Amended Complaint. The Parties further stipulate and respectfully request that the Court continue the initial case management conference currently scheduled for March 6, 2018 to May 4, 2018 and all related dates by sixty days.

IT IS SO STIPULATED.

DECLARATION REGARDING CONCURRENCE

Under N.D. Cal. Local Rule 5-1(i)(3), I attest that I obtained concurrence in the filing of this document from the other signatories listed here.

PROPOSED ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED. The County of Alameda is to answer or otherwise respond to Plaintiff's First Amended Complaint by April 27, 2018. The initial case management conference will be held on May 4, 2018, ADR deadlines are continued to April 13, 2018, and the last date to file a Rule 26(f) report is continued to April 27, 2018. The parties shall file a joint case management conference statement seven days prior to the initial case management conference.