Free Stipulation - District Court of California - California

Case 3:07-cv-05086-WHA

Document 56

Filed 09/02/2008

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1 EDMUND G. BROWN JR. Attorney General of the State of California 2 SUSAN M. CARSON Supervising Deputy Attorney General 3 GEORGE PRINCE, State Bar No. 133877 Deputy Attorney General 455 Golden Gate Avenue, Suite 11000 4 San Francisco, CA 94102-7004 Telephone: (415) 703-5749 5 Fax: (415) 703-5480 6 7 Attorneys for Defendants 8 9 10 11 12 13 14 v. 15 16 17 18 19 20 Based on this Court's July 3, 2008 order, dispositive motions in this action are to be JOHN A. WAGNER, Director of the California Department of Social Services, in his official capacity; GREG ROSE, Deputy Director of the Children and Family services Division of the California Department of Social Services, in his official capacity, Defendants. CALIFORNIA STATE FOSTER PARENT ASSOCIATION, CALIFORNIA STATE CARE PROVIDERS ASSOCIATION, and LEGAL ADVOCATES FOR PERMANENT PARENTING, Plaintiffs, C 07-5086 WHA STIPULATION AND [PROPOSED] ORDER RE: BRIEFING SCHEDULE ON DISPOSITIVE MOTIONS IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

21 filed no later than September 4, 2008, with the last day for hearing such motions set for October 22 9, 2008. (See Court's order of July 3, 2006 (Document 51 on electronic docket), a copy of 23 which is filed with this stipulation.) 24 The parties have conferred and hereby stipulate that the date by which dispositive

25 motions may be filed should be September 11, 2008. The parties further stipulate that the last 26 date for the hearing of those motions would remain as October 9, 2008. Accordingly, to retain 27 the briefing schedule dictated by the October 9, 2008 date, the parties further stipulate that 28 oppositions to the motions should be filed no later than September 18, 2008, with replies to those
Stipulation and [Proposed] Order re: Briefing Schedule California State Foster Parent Association, et al. v. Wagner C 07-5086 JL

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Case 3:07-cv-05086-WHA

Document 56

Filed 09/02/2008

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1 oppositions to be filed no later than September 25, 2008. Thus, no change is otherwise required 2 to the briefing or hearing schedule. 3 This request is based on medical situations facing two state officials indispensable to

4 the State's summary judgment motion, and is made in good faith and not for the purpose of delay 5 or for any improper purpose. 6 Accordingly, the parties respectfully request that the Court approve the stipulation and

7 make it the order of the Court. 8 9 10 11 12 13 14 15 16 17 18 19 GENERAL ORDER 45 ATTESTATION 20 I, George Prince, am the ECF user whose ID and password are being used to file this request for an order. In compliance with General Order 45, X.B., I hereby attest that Kimberly 21 N. Van Voorhis of Morrison & Foerster, LLP, has concurred in the filing of this document with her electronic signature. 22 Dated: September 2, 2008 23 /s/ George Prince 24 25 26 27 28
Stipulation and [Proposed] Order re: Briefing Schedule

Dated: September 2, 2008 Respectfully submitted. MORRISON & FOERSTER, LLP

By:

/s/ Kimberly N. Van Voorhis

Attorneys for Plaintiffs OFFICE OF THE CALIFORNIA ATTORNEY GENERAL By: /s/ George Prince, Deputy

Attorneys for Defendants

George Prince BASED ON THE STIPULATION OF THE PARTIES, IT IS SO ORDERED. DATED: ________________ ____________________________________ THE HONORABLE WILLIAM H. ALSUP UNITED STATES DISTRICT JUDGE
California State Foster Parent Association, et al. v. Wagner C 07-5086 JL

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