Stipulation and Order re: Extend Briefing Deadlines 

Pollar v. County of Alameda, et al. 

(Case No. 08-04196 BZ

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ROBERT R. POWELL, ESQ. CSB#159747 

DENNIS R. INGOLS, ESQ. CSB#236458 

LAW OFFICES OF ROBERT R. POWELL

925 West Hedding Street 

San José, California 95126 

T: 408-553-0200 F: 408-553-0203 

Attorneys for Plaintiffs 

DANIELLE POLLAR, SHALAWN POLLAR 

as Guardian Ad Litem for J.A., a minor 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF CALIFORNIA 

DANIELLE POLLAR, et al., ) Case No. 08-04196 BZ 

 ) 

 Plaintiffs, ) 

 ) STIPULATION FOR AN 

vs. ) ORDER TO EXTEND 

 ) BRIEFING DEADLINES 

COUNTY OF ALAMEDA, et al., ) 

 ) 

Defendants. ) 

_____ ) 

The parties hereto, by and through their respective counsel, do hereby stipulate and 

agree as set forth below on the following recital of facts and request this court order same: 

1. The current deadline for Plaintiffs’ Oppositions to the Amended Motions for 

Summary Judgment filed by the City Defendants (Docket #62) and County 

Defendants (Docket #66) is Friday, February 5, 2010, per Stipulation and 

Order (Docket #59). 

2. Plaintiffs will file the Opposition to the City Defendants’ Motion for Summary 

Judgment by the aforementioned deadline. 

Case 3:08-cv-04196-BZ Document 75 Filed 02/03/10 Page 1 of 3
Stipulation and Order re: Extend Briefing Deadlines 

Pollar v. County of Alameda, et al. 

(Case No. 08-04196 BZ

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3. Plaintiffs’ counsel will not be able to file Plaintiffs’ Opposition to County 

Defendants’ Motion for Summary Judgment by the deadline, due to two 

ongoing juvenile dependency trials, and a family law trial. 

4. First, in the case of Andrea N., Jadyn N., Ravyn N., Aaliyah K., Jasmine K., 

Gina K., Case #: 228331 through 228335, 228808, in Sacramento County 

Superior Court, the trial has been spread out over several days, with numerous 

delays and continuances, and has simply run longer than counsel originally 

estimated.1 The case has at least one days of trial remaining. 

5. Second, in Charley P., Kaylee R., Case # JD19508, JD19509, Plaintiffs’ 

counsel will be in trial at least half of the day on Tuesday, February 2, 2010, in 

Santa Clara County Superior Court. 

6. Third, in Delfino v. Collins, Case# 1-93 CP 001783, Plaintiffs’ counsel will be 

in trial on Friday, February 5, 2010, in Santa Clara County Superior Court. 

BASED on the foregoing recitals, the parties stipulate and request the court order that: 

1. The current deadline for Plaintiffs’ Opposition to County Defendants’ Motion for 

Summary Judgment is hereby continued from Friday, February 5, 2010, to Monday, 

February 8, 2010. 

2. The current deadline for County Defendants’ optional Reply brief is extended from 

Friday, February 19, 2010, to Monday, February 22, 2010.

Case 3:08-cv-04196-BZ Document 75 Filed 02/03/10 Page 2 of 3
Stipulation and Order re: Extend Briefing Deadlines 

Pollar v. County of Alameda, et al. 

(Case No. 08-04196 BZ

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 IT IS SO STIPULATED. 

Dated: 2/2/10 ___/S/ Robert R. Powell_______ 

 ROBERT R. POWELL, ESQ. 

 Attorney for Plaintiffs 

Dated: 2/2/10 __ /S/ Rebecca Widen_________ 

 REBECCA WIDEN, ESQ. 

 Attorney for County of Alameda, and 

 Individually Named Defendant 

 Employees of the County of Alameda 

Dated: 2/2/10 ___/S/ Patrick Co_____ _______

 Patrick Co 

Attorney for City of Hayward, 

Sam Sander and Mike Edwards

[PROPOSED] ORDER 

Based on the foregoing stipulation, and good cause appearing therefore, the 

Court hereby adopts the stipulation of the parties and orders as follows: 

1. The current deadline for Plaintiffs’ Opposition to County Defendants’ Motion for 

Summary Judgment is hereby continued from Friday, February 5, 2010, to Monday, 

February 8, 2010. 

2. The current deadline for County Defendants’ optional Reply brief is extended from 

Friday, February 19, 2010, to Monday, February 22, 2010.

 

IT IS SO ORDERED. 

Dated: ____/____/10 ____________________________ 

 JUDGE OF THE U.S. DISTRICT 

 COURT FOR THE NORTHERN 

 DISTRICT- SAN FRANCISCO 

 

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 In juvenile dependency matters, it is common for the court to assign separate case numbers for each child in a 

family, though they are heard as one single case. 

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Case 3:08-cv-04196-BZ Document 75 Filed 02/03/10 Page 3 of 3