________________________________________________________________________________________________________ 

STIPULATION AND [PROPOSED] ORDER RE: FILING OF FIRST 

AMENDED COMPLAINT 

Case No. CV 17-181 HSG 

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LOUIS A. LEONE, ESQ, (SBN: 099874) 

CLAUDIA LEED, ESQ. (SBN: 122676) 

SETH L. GORDON, ESQ. (SBN: 262653) 

LEONE & ALBERTS 

A Professional Corporation 

2175 N. California Blvd., Suite 900 

Walnut Creek, CA 94596 

Telephone: (925) 974-8600 

Facsimile: (925) 974-8601 

E-Mail: leonel@leonealberts.com

 cleed@leonealberts.com

sgordon@leonealberts.com

Attorneys for Defendants 

THE REGENTS OF THE UNIVERSITY OF CALIFORNIA 

and CYRIACUS NZEREM 

RAYMOND P. DOWD, PRO SE 

LAURA E. LINSER, PRO SE 

1770 Post Street, Suite 334 

San Francisco, CA 94115 

Telephone: (650) 787-8512 

Email: raydowd@me.com

 lelinser@me.com 

THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

RAYMOND P. DOWD and LAURA E. 

LINSER, 

 Plaintiffs, 

vs. 

UC REGENTS and CYRIACUS NZEREM 

and Does 1-10 inclusive, 

 Defendants. 

Case No.: CV 17-181 HSG 

STIPULATION AND [PROPOSED] 

ORDER RE: DEADLINE TO FILE 

FIRST AMENDED COMPLAINT AND 

RESPONSE THERETO 

Defendants, who are represented by their undersigned counsel, hereby 

stipulate with Plaintiffs, who appear Pro Se, as follows: 

WHEREAS, Defendants filed a Motion to Dismiss Plaintiffs’ Original Complaint 

on February 23, 2017. 

Case 4:17-cv-00181-HSG Document 10 Filed 03/14/17 Page 1 of 4
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STIPULATION AND [PROPOSED] ORDER RE: FILING OF FIRST 

AMENDED COMPLAINT 

Case No. CV 17-181 HSG 

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WHEREAS, the hearing on the Motion to Dismiss is scheduled for April 20, 

2017. 

WHEREAS, the deadline for Plaintiffs to file their opposition to the Motion to 

Dismiss is February 27, 2017. 

WHEREAS, Plaintiffs intend to file a First Amended Complaint instead of filing an 

opposition to the pending Motion to Dismiss. 

WHEREAS, the parties have agreed to request that the Court extend the 

deadline for the Plaintiffs’ to file their First Amended Complaint and for Defendants to 

respond to the First Amended Complaint. 

IT IS HEREBY STIPULATED, as follows: 

1. Plaintiffs shall dismiss The Regents from the First Cause of Action for 

violation of the Fourth Amendment with prejudice. 

2. Plaintiffs shall dismiss the Second Cause of Action for violation of Equal 

Protection with prejudice in its entirety. 

3. In consideration of Plaintiffs dismissing The Regents from the First of 

Action and dismissing the Second Cause of Action in its entirety, Defendants agree that 

the deadline for Plaintiffs to file their First Amended Complaint is extended to March 6, 

2017. 

4. Plaintiffs agree that the deadline for Defendants to file a responsive 

pleading to the First Amended Complaint shall be March 27, 2017. 

5. Plaintiffs do not waive their right to plead in their First Amended 

Complaint additional state causes of actions against The Regents. 

6. Defendants do not waive their right to file a renewed Motion to Dismiss 

on any ground in response to the First Amended Complaint including those grounds 

asserted in response to the Original Complaint. 

7. If Plaintiffs file their First Amended Complaint on or by March 6, 2017, 

Defendants agree to withdraw their pending Motion to Dismiss. 

/// 

Case 4:17-cv-00181-HSG Document 10 Filed 03/14/17 Page 2 of 4
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STIPULATION AND [PROPOSED] ORDER RE: FILING OF FIRST 

AMENDED COMPLAINT 

Case No. CV 17-181 HSG 

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8. If Plaintiffs fail to file the First Amended Complaint on or by March 6, 

2017, the hearing on Defendants’ Motion to Dismiss shall remain on calendar and the 

deadline for Defendants’ to file their Reply Brief shall be March 27, 2017. 

9. Plaintiffs shall file a motion and Proposed Order for permission for 

Electronic Case Filing by March 1, 2017. 

IT IS SO STIPULATED.

Dated: February 24, 2017 

By:____/s/ Raymond Dowd_______________

 RAYMOND DOWD, PRO SE 

Dated: February 24, 2017 

By:___/s/ Laura E. Linser_________________

 LAURA E. LINSER, PRO SE 

Dated: February 24, 2017 LEONE & ALBERTS 

By:_/s/ Claudia Leed, Esq._______________

 LOUIS A. LEONE, ESQ. 

 CLAUDIA LEED, ESQ. 

 SETH L. GORDON, ESQ. 

 Attorneys for Defendants 

 THE REGENTS OF THE UNIVERSITY OF 

 CALIFORNIA and CYRIACUS NZEREM 

ORDER

Pursuant to the Stipulation of the Parties and good cause appearing it is hereby 

ordered as follows: 

1. The First Cause of Action is dismissed with Prejudice against The 

Regents. 

2. The Second Cause of Action is dismissed in its entirety with prejudice. 

3. The deadline for Plaintiffs to file their First Amended Complaint is 

extended to March 6, 2017. 

4. The deadline for Defendants to file a responsive pleading to the First 

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STIPULATION AND [PROPOSED] ORDER RE: FILING OF FIRST 

AMENDED COMPLAINT 

Case No. CV 17-181 HSG 

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Amended Complaint shall be March 27, 2017. 

5. The hearing on Defendants pending Motion to Dismiss shall be vacated 

upon the filing of Plaintiffs’ First Amended Complaint on or by March 6, 2017. 

6. If Plaintiffs fail to file the First Amended Complaint on or by March 6, 

2017, the hearing on Defendants’ Motion to Dismiss shall remain on calendar and the 

deadline for Defendants’ to file their Reply Brief shall be March 27, 2017. 

7. Plaintiffs shall file a motion and Proposed Order for permission for 

Electronic Case Filing by March 1, 2017. 

IT IS SO ORDERED. 

Dated: _____________, 2017 _________________________________ 

 HON. HAYWOOD S. GILLIAM 

 Judge of the District Court 

, JR. March 14

Case 4:17-cv-00181-HSG Document 10 Filed 03/14/17 Page 4 of 4