Free Declaration in Support - District Court of California - California

Case 3:07-cv-02928-JSW

Document 42

Filed 08/29/2008

Page 1 of 2

1 EDMUND G. BROWN JR. Attorney General ofthe State of California 2 DAVID S. CHANEY Chief Assistant Attorney General 3 ROCHELLE C. EAST Senior Assistant Attorney General 4 MICHAEL W. JORGENSON Supervising Deputy Attorney General 5 JENNIFER 1. NYGAARD, State Bar No. 229494 Deputy Attorney General 6 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 7 Telephone: (415) 703-5577 Fax: (415) 703-5843 8 Email: [email protected] 9 Attorneys for Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Klein 10
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IN THE UNITED STATES DISTRICT COURT 12 FORTHE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION 14 15 ,16 17 18 19 20 21 1,1. Nygaard, declare as follows:
)

RONALD BRATTON, ,
Plaintiff,

C 07-2928 JSW

v.
BEN CURRY, ET AL.,
Defendants.

DECLARATION OF J. NYGAARD IN SUPPORT OF DEFENDANTS'REQUEST FOR EXTENSION OF TIME

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1.

I am employed by the Office of the California Attorney General as a Deputy Attorney

General in the Correctional Law Section. Lisa Sciandra, the Deputy Attorney General assigned to represent Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Klein (Defendants) in this case, is currently on medical leave. 2. Defendants filed motions to dismiss and for summary judgment on June 23,2008. On

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27 May 19,2008, this Court ordered Defendants to file a reply brief no later than fifteen days after

28 Plaintiffs opposition to Defendants' motions to dismiss and summary judgment is filed. After
Decl. J. Nygaard Supp. Defs.' Rqst. EOT
Bratton v. Curry, et al. e 07-2928 JSW

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Case 3:07-cv-02928-JSW

Document 42

Filed 08/29/2008

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,
1 receiving two extensions of time, Plaintiffs opposition was filed August 26,2008.
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3.

Ms. Sciandra has been on medical leave since July 21, 2008, and is expected to return

3 on September 2, 2008. Ms. Sciandra has reply briefs in two other cases in the United States 4 District Court, Northern District of California dueSeptember 10, 2008, and September 15, 2008. 5 She also has an answering brief in a case in the Ninth Circuit due October 14, 2008. An 6 extension of time for Defendants to file their reply brief up to and including October 10, 2008, 7 should provide Ms. Sciandra sufficient time to prepare a reply upon returning from medical 8 leave. 9 10 4. 5. Plaintiffis a state prisoner and cannot be easily contacted about an extension of time.. Defendants previously received two extensions of time in which to file a dispositive

11 motion. Plaintiff also received two extensions of time in which to file his·opposition to 12 Defendants motions to dismiss and summary judgment.
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6.

This request for extension oftime is not made for any purpose of harassment or undue
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14 delay, or for any improper reason. 15 16 I declare under penalty of perjury that the foregoing is true and correct to the best of my

17 knowledge, and that this declaration was executed on August 29,2008, in San Francisco, 18 19 20 21 22 23
20137737.wpd
i"

California.

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SF2008400402

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Dec!' 1. Nygaard Supp.Defs.' Rqst. EOT

Bratton v. Curry, et al.

e 07-2928 JSW

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