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Elisa Ramirez, Guardian Ad Litem For A.S., Minor v. County of Alameda

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


November 1, 2012

ELISA RAMIREZ, GUARDIAN AD LITEM FOR A.S., MINOR, PLAINTIFF,
v.
COUNTY OF ALAMEDA, ALAMEDA COUNTY SHERIFF'S DEPT., GREGORY AHERN, SHERIFF, DEFENDANTS.

STIPULATED REQUEST TO EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER

The parties in the above-captioned case, by and through their counsel of record, hereby represent 22 to the Court as follows: 23

1. On September 14, 2012, Plaintiff filed the Complaint initiating the above-captioned action 24 against the County of Alameda, Alameda County Sheriff's Department and Sheriff Gregory Ahern. 25

2. On September 27, 2012, Plaintiff served the Complaint on the County of Alameda, Alameda County Sheriff's Department and Sheriff Gregory Ahern by personal service. 27

3. Defendants County of Alameda, Alameda County Sheriff's Department and Sheriff Gregory Ahern's last day to file a responsive pleading to the Complaint was October 18, 2012.

4. By Order dated October 25, 2012, this Court approved the parties' stipulation extending defendants' time to respond to the complaint to November 1, 2012. 3

5. On October 26, 2012 counsel for defendants sent meet and confer correspondence to plaintiff's counsel regarding requesting plaintiff dismiss certain causes of action from the complaint in an 5 effort to avoid a motion to dismiss. 6

6. While the parties have agreed on most issues raised in that correspondence, counsel for plaintiff needs additional time to complete review of the correspondence and, if necessary, draft a first 8 amended complaint. 9

7. The parties therefore stipulate to extend the time for defendants to respond to the Complaint through and including November 15, 2012. An extension of this length will not interfere with 11 any deadlines currently pending on the Court's calendar. 12 13

DATED: October 31, 2012 LAW OFFICES OF JOHN L. BURRIS 14 By: /s/ DeWitt Lacy John L. Burris DeWitt Lacy Attorneys for Plaintiff ELISA RAMIREZ, Guardian ad Litem for A.S., minor DATED: October 31, 2012 BERTRAND, FOX & ELLIOT By: /s/ Michael C. Wenzel Thomas F. Bertrand Michael C. Wenzel Attorneys for Defendants COUNTY OF ALAMEDA, ALAMEDA COUNTY SHERIFF'S DEPARMENT and GREGORY AHERN

ORDER

Upon the foregoing Stipulation, and for good cause shown, IT IS ORDERED that the time for Defendant to respond to the Complaint shall be extended to November 15, 2012.

Dated: October ___, 2012

UNITED STATES CHIEF MAGISTRATE JUDGE

20121101

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