Reynoso v. Sayre et al
Filing
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ORDER by Judge Claudia Wilken Granting 17 Motion for Extension of Time to File. (Attachments: # 1 Certificate/Proof of Service) (ndr, COURT STAFF) (Filed on 8/24/2012) Modified on 8/24/2012 (ndr, COURT STAFF). ***DISREGARD, SEE DOCKET NO. 19 FOR ORDER***
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R I V E R A & A S S O C I AT E S
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2180 Harvard Street, Suite 310
Sacramento, California 95815
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Tel: 916-922-1200 Fax: 916 922-1303
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Jesse M. Rivera, CSN 84259
Shanan L. Hewitt, CSN 200168
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Jonathan B. Paul, CSN 215884
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Attorneys for Defendants,
Michael Sayre, Laurie Thomas, Adams, Jacquez F.
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IN THE UNITED STATES DISTRICT COURT
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IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OMAR REYNOSO,
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Plaintiff,
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vs.
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CHIEF MEDICAL OFFICER MICHAEL
SAYRE, et al.
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Defendants.
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CASE NO. 4:11-cv-4525-CW (PR)
DEFENDANTS’ REQUEST FOR AN
ENLARGEMENT OF TIME TO FILE
DISPOSITIVE MOTIONS
RESPONDENTS SAYRE, THOMAS, ADAMS, and JACQUEZ F., hereby respectfully
request the Court grant them an enlargement of time of 90 days to file dispositive motions.
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Due to numerous conflicts by the Attorney General’s office our office has been assigned
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conflicts and overflow cases. Due to the Plaintiff having been moved from one prison facility to
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another there are numerous witnesses to interview and voluminous medical records to examine.
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Thus, we are requesting additional time for the discovery process.
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We are hereby requesting a short continuance of the dispositive motion deadline of 90 days
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up to December 7, 2012, to file dispositive motions. We do not believe plaintiff will be prejudiced
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by this short delay, nor will this require a resetting of any trial or pretrial hearing.
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Defendants’ Request for an Enlargement of Time to File Dispositive Motions
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August 13, 2012
Respectfully submitted,
RIVERA & ASSOCIATES
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/s/ Jesse M. Rivera
JESSE M. RIVERA
Attorney for Respondents
Michael Sayre, Laurie Thomas, Adams and
Jacquez F.
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Defendants’ Request for an Enlargement of Time to File Dispositive Motions
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DECLARATION OF JESSE M. RIVERA
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I, JESSE M. RIVERA, hereby declare:
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1.
That I am licensed to practice in all of the courts of the State of California and am
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also authorized to practice in the Federal District Court, Eastern District, State of
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California, as well as the Northern and Central District, State of California. I am
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also authorized to practice in the Ninth and the Eleventh Circuit District Court, and
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the United States Supreme Court;;
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2.
That I am a principal with the law firm of RIVERA & ASSOCIATES;
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3.
Due to numerous conflicts by the Attorney General’s office our office has been
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assigned conflicts and overflow cases;
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Due to numerous conflicts by the Attorney General’s office our office has been
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assigned conflicts and overflow cases. Due to the Plaintiff having been moved from
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one prison facility to another there are numerous witnesses to interview and
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voluminous medical records to examine. Thus, we are requesting additional time for
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the discovery process;
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That I have taken the deposition of the Plaintiff, Omar Reynoso on August 9, 2012;
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That I have personal knowledge of the facts stated in this declaration and, if
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called as a witness, could and would testify to those facts;
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We are hereby requesting a short continuance of the dispositive motion deadline of
90 days up to December 7, 2012, to file dispositive motions;
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We do not believe plaintiff will be prejudiced by this short delay, nor will this
require a resetting of any trial or pretrial hearing.
I declare under penalty of perjury under the laws of the State of California that the foregoing
is true and correct.
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Dated: August 13, 2012
/s/ Jesse M. Rivera
JESSE M. RIVERA
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Defendants’ Request for an Enlargement of Time to File Dispositive Motions
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IN THE UNITED STATES DISTRICT COURT
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IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA
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OMAR REYNOSO,
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Plaintiff,
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vs.
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CHIEF MEDICAL OFFICER MICHAEL
SAYRE, et al.
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CASE NO. 4:11-cv-4525-CW (PR)
DEFENDANTS’ REQUEST FOR AN
ORDER ON DEFENDANTS' REQUEST
ENLARGEMENT OF TIME TO FILE
FOR AN ENLARGEMENT
DISPOSITIVE MOTIONSOF TIME TO
FILE DISPOSITIVE MOTIONS
Defendants.
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Good cause here appearing, Defendants’ request for an extension of time to file dispositive
motions is granted.
IT IS HEREBY ORDERED that defendants have until December 7, 2012, to file dispositive
motions.
Plaintiff's opposition will be due no later than 28 days after the dispositive motion
is filed, and Defendants shall file a reply no later than 14 days after the opposition is filed.
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_______________________________
The Honorable Claudia Wilken
United States District Judge
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Defendants’ Request for an Enlargement of Time to File Dispositive Motions
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Omar Reynoso v. Chief Medical Officer Michael Sayre, et al
U.S. District Court, Northern District, Oakland
Case Number: 4:11-cv-04525-CW (PR)
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PROOF OF SERVICE
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I am a citizen of the United States, employed in the City and County of Sacramento. My
business address is 2180 Harvard Street, Suite 310, Sacramento, California, 95815. I am over the
age of 18 years and not a party to the above-entitled action.
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I am familiar with RIVERA & ASSOCIATES’ practice whereby the mail is sealed, given
the appropriate postage and placed in a designated mail collection area. Each day's mail is collected
and deposited in a U.S. mailbox after the close of each day's business.
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On the following date, I served the attached:
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DEFENDANTS’ REQUEST FOR AN ENLARGEMENT OF TIME TO FILE
DISPOSITIVE MOTIONS
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on all parties who have appeared via electronic mail through CM/ECF.
on the parties in this action, who do not appear via electronic mail, by causing a true
copy thereof to be placed in a sealed envelope with postage thereon fully prepaid in the
designated area for outgoing mail.
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on all other the parties in this action by causing a true copy thereof to be telecopied by
facsimile to the attorneys of record in the above action.
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(By Express Mail pursuant to Code of Civil Procedure section 1013.) I deposited each
sealed envelope, with the postage prepaid, to be delivered via Federal Express to the
party(ies) so designated on the service list.
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PRO SE
Omar Reynoso
H-93482
C4-109
Pelican Bay State Prison
P.O. Box 7500
Crescent City, CA 95532
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I declare under penalty of perjury that the foregoing is true and correct and that this Declaration
is executed August 13, 2012, at Sacramento, California.
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/s/ Rhonda Harrigan
Rhonda Harrigan
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Defendants’ Request for an Enlargement of Time to File Dispositive Motions
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