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

Case 3:08-cv-00891-JAH-POR

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Filed 06/20/2008

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MICHAEL J. AGUIRRE, City Attorney DONALD F. SHANAHAN, Deputy City Attorney California State Bar No. 49777 Office of the City Attorney 1200 Third Avenue, Suite 1100 San Diego, California 92101-4100 Telephone: (619) 533-5800 Facsimile: (619) 533-5856 Attorneys for Defendants Franklin White, William Lansdowne, San Diego Police Department and City of San Diego

Exempt from fees per Gov't code 6103 To the benefit of the City of San Diego

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case No. 08cv0891 JAH (POR) JOINT MOTION TO EXTEND TIME TO FILE RESPONSIVE PLEADING

10 JOHNNY SILVA, an individual and minor, by ) and through his guardian ad litem, LUIS SILVA, ) ) 11 Plaintiff, ) ) 12 v. ) ) 13 FRANKLIN WHITE, an individual, WILLIAM ) ) 14 LANSDOWNE, an individual, SAN DIEGO POLICE DEPARTMENT, CITY OF SAN ) ) 15 DIEGO, and DOES 1 - 20, ) Defendants. ) 16 ) 17 18 19 20 21 22 23 24 25 26 27 28

Judge: Courtroom:

John A. Houston 11

PLEASE TAKE NOTICE that Eugene Iredale, Attorney for JOHNNY SILVA, an individual and minor, by and through his guardian ad litem, LUIS SILVA (Plaintiff) and Donald F. Shanahan, Deputy City Attorney, for FRANKLIN WHITE, WILLIAM LANSDOWNE, SAN DIEGO POLICE DEPARTMENT and CITY OF SAN DIEGO (Defendants), hereby stipulate to an extension of time within which to file a response for all defendants to the Summons and /// /// /// /// /// /// 1
08cv0891 JAH (POR)

Case 3:08-cv-00891-JAH-POR

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Filed 06/20/2008

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Complaint served upon the City of San Diego on May 22, 2008, in order that investigation into the representation of all parties by the City Attorney's office can be completed. IT IS HEREBY STIPULATED. Dated: June 20, 2008 By /s/ Eugene Iredale Eugene Iredale

Attorneys for Plaintiff Johnny Silva, an individual and minor, by and through his Guardian ad Litem, Luis Silva

Dated: June 20, 2008

MICHAEL J. AGUIRRE, City Attorney

By

/s/ Donald F. Shanahan Donald F. Shanahan Deputy City Attorney

Attorneys for Defendants City of San Diego

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08cv0891 JAH (POR)

Case 3:08-cv-00891-JAH-POR

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Filed 06/20/2008

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 JOHNNY SILVA, etc. Plaintiff, v.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case No.: 08cv0891 JAH (POR) DECLARATION OF SERVICE

CITY OF SAN DIEGO, et al., Defendants. I, the undersigned, declare under penalty of perjury that I am over the age of eighteen years and not a party to this action; and that I served the individuals on the service list attached hereto the following documents: JOINT MOTION TO EXTEND TIME TO FILE RESPONSIVE PLEADING, in the following manner: (Check one) 1) By personally serving the individual named by personally delivering the copies to the offices of the addressee. Time of delivery: ___________ a.m./p.m. 2)___ By leaving, during usual office hours, copies in the office of the person served with the person who apparently was in charge and thereafter mailing copies (first class mail, postage prepaid) to the person served at the place where the copies were left. 3) XX By electronic filing, I served each of the above referenced documents by E filing, in accordance with the rules governing the electronic filing of documents in the United States District Court for the Southern District of California, as to the following parties: Eugene Iredale [email protected], [email protected]

Executed: June 20, 2008, at San Diego, California.

SHELLEY CARTER

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08cv0891 JAH (POR)