Free Motion for Extension of Time to File - District Court of California - California

Case 3:07-cv-02928-JSW

Document 18

Filed 05/01/2008

Page 1 of 3

1 EDMUND G. BROWN JR. Attorney General of the State of California 2 DAVID S. CHANEY Chief Assistant Attorney General 3 FRANCEST.GRUNDER Senior Assistant Attorney General 4 MICHAEL W. JORGENSON Supervising Deputy Attorney General 5 LISA SCIANDRA, State Bar No. 246532 Deputy Attorney General 6 455 Golden Gate Avenue, Suite 11000 San Francisco, CA 94102-7004 7 Telephone: (415) 703-5846 . Fax: (415) 703-5480 8 Email: [email protected] . 9 Attorneys for Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Kleinl / 10 11 IN THE UNITED STATES DISTRICT COURT 12 FOR THE NORTHERN DISTRICT OF CALIFORNIA
13

SAN FRANCISCO DIVISION 14 15 16 17 18 19 20 21 Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Klein RONALD BRATTON, Plaintiff, Case No. C 07-2928 JSW DEFENDANTS' REQUEST FOR A FORTY-FIVE-DAY EXTENSION OF TIME TO FILE DISPOSITIVE MOTION

v.
BEN CURRY, et al. Defendants.

22 (Defendants) respectfully request that this Court grant a forty-five-day extension of time, up to 23 and including June 23, 2008, in which to file a motion for summary judgment or other dispositive 24 III 25 III 26 27 1. To the best knowledge of the Attorney General's Office, Defendant Jannah has not been 28 served. Accordingly, the Attorney General's Office makes no appearance on his behalf.
Defs.' Req. for 45-Day Ext. of Time to File Dispositive Mot.

R. Bratton v. B. Curry, et al. C 07-2928 JSW

1

Case 3:07-cv-02928-JSW

Document 18

Filed 05/01/2008

Page 2 of 3

1 motion. As explained more fully in counsel's accompanying declaration, this extension will 2 allow counsel time to gather sufficient documents and information to determine and prepare an 3 appropriate response to this lawsuit.

4 5 6 7 8 9 10
11

Dated: May 1; 2008 Respectfully submitted, EDMUND G. BROWN JR. Attorney General of the State of California DAVID S. CHANEY Chief Assistant Attorney General FRANCEST.GRUNDER Senior Assistant Attorney General MICHAEL W. JORGENSON Supervising Deputy Attorney General

12
13

-: .r>:>
LISA SCIANDRA Deputy Attorney General Attorneys for Defendants Curry, Chudy, Hill, Hedrick, Raghunath, Grannis, Aboytes, and Klein
40248088.wpd SF2008400402

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Defs.' Req. for 45-Day Ext. of Time to File Dispositive Mot.

R. Bratton v. B. Curry, et al. e 07-2928 JSW

2

Case 3:07-cv-02928-JSW

Document 18

Filed 05/01/2008

Page 3 of 3

DECLARATION OF SERVICE BY U.S. MAIL
Case Name: No.:

R. Bratton v. B. Curry, et al.

C 07-2928 JSW

I declare: I am employed inthe Office of the Attorney General, which is the office of a member of the .' California State Bar, at which member's direction this service is made. I am 18 years of age or' older and not a party to this matter. I am familiar with the business practice at the Office of the Attorney General for collection and processing of correspondence for mailing with the United .States Postal Service. In accordance with that practice, correspondence placed in the internal mail collection system at the Office of the Attorney General is deposited with the United States Postal Service that same day in the ordinary course of business. On May 1,2008, I served the attached

DEFENDANTS' REQUEST FOR A FORTY-FIVE-DAY EXTENSION OF TIME TO FILE DISPOSITIVE MOTION DECLARATION OF COUNSEL IN SUPPORT OF DEFENDANTS' REQUEST FOR AN EXTENSION OF TIME TO FILE DISPOSITIVE MOTION [PROPOSED] ORDER GRANTING DEFENDANTS' REQUEST FOR A FORTY-FlVEDAY EXTENSION OF TIME TO FILE DISPOSITIVE MOTION
by placing a true copy thereof enclosed in a sealed envelope with postage thereon fully prepaid, in the internal mail collection system at the'Office ofthe Attorney General at 455 Golden Gate Avenue, Suite 11000, San Francisco, CA 94102-7004, addressed as follows: Ronald Bratton (J-45341) Correctional Training Facility P.O. Box 689 Soledad, CA 93960-0689 In pro per
'I
.
\
"

I declare under penalty of perjury under the laws of the State of California the foregoing is true and correct and that this declaration was executed on May 1,2008, at San Francisco, California.

M. Luna Declarant
40248504,wpd

Signature