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Stipulation and Order re Extending Time for Opposition.

OFFICE OF THE COUNTY COUNSEL

County of San Joaquin

DANIEL C. CEDERBORG, CSB #124260

Deputy County Counsel

JASON R. MORRISH, CSB#192686

Deputy County Counsel

Courthouse - Room 711

222 East Weber Avenue

Stockton, California 95202

Telephone: (209) 468-2980

Attorneys for Defendants, 

 COUNTY OF SAN JOAQUIN, SHERIFF BAXTER

 DUNN and SHERIFF’s DEPARTMENT

 OF SAN JOAQUIN COUNTY

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

ROBERT T. BROWN, individually and on

behalf of Class of Persons similarly situated,

 

Plaintiff, 

vs.

COUNTY OF SAN JOAQUIN, SHERIFF

BAXTER DUNN, SHERIFF’S DEPARTMENT

OF SAN JOAQUIN COUNTY and DOES I

through X inclusive,

 

 Defendants.

CASE NO. CIV.S-04-2008 FCD PAN (JFM)

 

STIPULATED ORDER EXTENDING

TIME FOR OPPOSITION ON

COUNTY MOTION FOR SUMMARY

JUDGMENT

 

 

Plaintiff ROGER T. BROWN and Defendants COUNTY OF SAN JOAQUIN, SHERIFF

BAXTER DUNN, DEPUTY RICHARD DUNSING, DEPUTY SEMILLO, DEPUTY

MENDEZ, and LT. MENDOZA, by and through their respective counsel, respectfully submit

this STIPULATED ORDER EXTENDING TIME FOR OPPOSITION ON COUNTY MOTION

FOR SUMMARY JUDGMENT for consideration by the Court. The Court has previously set

the hearing on the County Defendant’s motion for summary judgment on April 21, 2006. 

According to the court’s local rules, Plaintiff’s Opposition would be due on April 7, 2006.

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Stipulation and Order re Extending Time for Opposition.

Because Plaintiff’s counsel, Mr. Nickerson, departs for Turkey this week and will not be

returning to this country from Turkey until April 5, 2006, the parties believe that good cause

exists for allowing Plaintiff a few days extra time to file and serve the Opposition papers. The

parties have met and conferred and have agreed to narrowing the matters at issue on this trial by

dismissing certain defendants and some of the causes of action.

STIPULATION

The Parties hereby stipulate and request the Court order as follows:

1. Defendants shall serve and file by electronic means their Motion for Summary

Judgment by March 21, 2006 in conformance with all local rules of court.

2. Plaintiff shall have until April 11, 2006 at 4:00 p.m. to file and serve by electronic

means Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment. Plaintiff shall also

fax a copy of the Opposition papers to defense counsel by the close of business on April 11,

2006.

3. All other filing and service deadlines relevant to the Defendants’ Motion for

Summary Judgment shall remain unaltered and Defendants shall file and serve their Reply

papers, if any, by April 14, 2006.

WHEREFORE, the parties stipulate to and request from the Court an order as follows:

1. Plaintiff shall have until April 11, 2006 at 4:00 p.m. to file and serve by electronic

means Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment. Plaintiff shall also

fax a copy of the Opposition papers to defense counsel by the close of business on April 11,

2006.

2. All other filing and service deadlines relevant to the Defendants’ Motion for

Summary Judgment shall remain unaltered and Defendants shall file and serve their Reply

papers, if any, by April 14, 2006.

/ / /

/ / /

[Signatures and Proposed Order on Next Page]

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Stipulation and Order re Extending Time for Opposition.

Respectfully submitted,

OFFICE OF THE COUNTY COUNSEL

Dated: March 20, 2006 By: /s/ Daniel C. Cederborg 

DANIEL C. CEDERBORG

 Deputy County Counsel

Attorneys for Defendants,

COUNTY OF SAN JOAQUIN, SHERIFF

BAXTER DUNN and SHERIFF’S

DEPARTMENT OF SAN JOAQUIN

COUNTY

Dated: March 20, 2006

By: /s/ Bruce W. Nickerson 

BRUCE W. NICKERSON 

 Attorney at Law

Attorney for Plaintiff,

ROBERT T. BROWN

ORDER OF THE COURT

The Parties to this action having stipulated to an extension for the filing and service of

Plaintiff’s opposition to the Defendants’ motion for summary judgment and/or summary

adjudication, and good cause appearing,

IT IS HEREBY ORDERED THAT:

1. Plaintiff shall have until April 11, 2006 at 4:00 p.m. to file and serve by electronic

means Plaintiff’s Opposition to Defendant’s Motion for Summary Judgment. Plaintiff shall also

fax a copy of the Opposition papers to defense counsel by the close of business on April 11,

2006.

2. All other filing and service deadlines relevant to the Defendants’ Motion for

Summary Judgment shall remain unaltered and Defendants shall file and serve their Reply

papers, if any, by April 14, 2006.

Date: March 21, 2006 /s/ Frank C. Damrell Jr. 

Hon. Frank C. Damrell, Jr.

United States District Judge

Case 2:04-cv-02008-FCD-EFB Document 26 Filed 03/21/06 Page 3 of 3