MOTION for Extension of Time to File Response/Reply by Solana Beach School District, Mary Ellen Nest. (Attachments: # (1) Stipulation)(Creighton, Jennifer) (mkz).
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Case 3:08-cv-00622-W-POR Document4 Filed 06/23/2008 Page 1 of3
JENNIFER S$. CREIGHTON, STATE BAR NO. 202799
WINET, PATRICK & WEAVER
SOUTH MELROSE DRIVE, SUITE 200
VISTA, CALIFORNIA 9208 | -6666
TELEPHONE: (760) 758-4261
Attorneys for Defendants Solana Beach Schoo! District and Mary Ellen Nest
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
Ka.D., a minor, by her mother, Ky.D., as her CASE NO. '08 CV 0622 JLS POR
next friend; Ky.D. and B.D., ACTION DATE:
Plaintiffs, VC JUDGE:
vs. JOINT MOTION TO CONTINUE
DEFENDANTS' DEADLINE TO FILE
SOLANA BEACH SCHOOL DISTRICT and RESPONSIVE PLEADING
MARY ELLEN NEST,
Defendants.
Defendants, SOLANA BEACH SCHOOL DISTRICT and MARY ELLEN NEST, and
Plaintiffs, Ka.D., a minor, by her mother, Ky.D., as her next friend; Ky.D. and B.D., jointly agree
to move to continue the deadline for Defendants to file a responsive pleading and any
counterclaims to Plaintiffs’ Complaint. Please see attached Stipulation.
Dated:_(y L23| OX WINET, PATRICK & WEAVER
By:
Jebsifer S. Qeightoh, Attorneys for
Defendants, each Schoo! District and
Mary Ellen Nest
JOINT MOTION TO CONTINUE DEFENDANTS' DEADLINE TO FILE RESPONSIVE PLEADING
CASE NO, '08 CV 0622 JLS PORPage 2 m:Law Offices of Maureen Graves (17607586420) 14:49 06/23/08GMT-04 Pg 03-03/23/2008 1CaRerRBrey-ON62eW-POR »ecumente vealed 06/23/2008 Page 4a2bF/o08
Dated: GLI Q fg LAW OFFICES OF MAUREEN GRAVES By: Deron. Gnd
Maureen Graves, Allorneys for Plainti (ts Ka.l,, a minor, by her mother, Ky.D.. as her
next friend: Ky. 2. and B.D.
tm
VK DEFENDANTS DEADLINE TO FILE RESPONSIVE PLEADING |
CASE NQ. 08 CV 0622 JES FOR |
i
JOIN MOTION FO CONPage 3 Case 3:08-cv-00622-W-POR Document4 Filed 06/23/2008 Page3of3
Ka.D., v. Solana Beach School District and Mary Ellen Nest (GI20546)
United States District Court, Southern District of California, Case No. 08 CV0622 JLS (POR)
JENNIFER S. CREIGHTON, STATE BAR NO. 202799
WINET, PATRICK & WEAVER
S. MELROSE DRIVE, SUITE 200
VISTA, CALIFORNIA 92081
TELEPHONE: (760) 758-4261
CERTIFICATE OF SERVICE
I, Vicki Asturias, declare:
Iam employed in the County of San Diego, State of California. I am over the age of 18
and not a party to the within action. My business address is 440 South Melrose Drive, Suite 200,
Vista, California 92081.
On June 23, 2008, I served the foregoing documents:
JOINT MOTION TO CONTINUE DEFENDANTS' DEADLINE TO FILE
RESPONSIVE PLEADING
on all interested persons in this action addressed as shown below and on the attached service list
which is incorporated herein as follows:
Q BY MAIL: By placing an envelope for collection and mailing following our ordinary
business practices. I am readily familiar with the firm's practice of collection and
processing of correspondence for mailing with the United States Postal Service, and that
the correspondence shall be deposited with the United States Postal Service this same day
in the ordinary course of business in a sealed envelope with first-class postage prepaid at
Vista, California.
(X) BY ELECTRONIC SERVICE: On the dated stated above, I served the documents via
CM/ECF described above on designated recipients through electronic transmission of
said documents; a certified receipt is issued to filing party acknowledging receipt by
CM/ECF's system. Once CM/ECF has served all designated recipients, proof of
electronic service is returned to the filing party.
I declare under the penalty of perjury under the laws of the State of California that the
foregoing is true and correct. I declare that I am employed in the office of a member of the bar of
this court at whose direction the service was made.
Executed on June 23, 2008, at Vista, California.
\al -Catnnag
Vicki Asturias
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Case 3:08-cv-00622-W-POR Document4 Filed 06/23/2008 Page 1 of3
JENNIFER S$. CREIGHTON, STATE BAR NO. 202799
WINET, PATRICK & WEAVER
440 SOUTH MELROSE DRIVE, SUITE 200
VISTA, CALIFORNIA 9208 | -6666
TELEPHONE: (760) 758-4261
Attorneys for Defendants Solana Beach Schoo! District and Mary Ellen Nest
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
Ka.D., a minor, by her mother, Ky.D., as her CASE NO. '08 CV 0622 JLS POR
next friend; Ky.D. and B.D., ACTION DATE:
Plaintiffs, VC JUDGE:
vs. JOINT MOTION TO CONTINUE
DEFENDANTS' DEADLINE TO FILE
SOLANA BEACH SCHOOL DISTRICT and RESPONSIVE PLEADING
MARY ELLEN NEST,
Defendants.
Defendants, SOLANA BEACH SCHOOL DISTRICT and MARY ELLEN NEST, and
Plaintiffs, Ka.D., a minor, by her mother, Ky.D., as her next friend; Ky.D. and B.D., jointly agree
to move to continue the deadline for Defendants to file a responsive pleading and any
counterclaims to Plaintiffs’ Complaint. Please see attached Stipulation.
Dated:_(y L23| OX WINET, PATRICK & WEAVER
By:
Jebsifer S. Qeightoh, Attorneys for
Defendants, each Schoo! District and
Mary Ellen Nest
1
JOINT MOTION TO CONTINUE DEFENDANTS' DEADLINE TO FILE RESPONSIVE PLEADING
CASE NO, '08 CV 0622 JLS POR
PDF Page 3
m:Law Offices of Maureen Graves (17607586420) 14:49 06/23/08GMT-04 Pg 03-03
06/23/2008 1CaRerRBrey-ON62eW-POR »ecumente vealed 06/23/2008 Page 4a2bF/o08
Dated: GLI Q fg LAW OFFICES OF MAUREEN GRAVES
3 By: Deron. Gnd
Maureen Graves, Allorneys for Plainti (ts
4 Ka.l,, a minor, by her mother, Ky.D.. as her
next friend: Ky. 2. and B.D.
tm
0
VK DEFENDANTS DEADLINE TO FILE RESPONSIVE PLEADING |
CASE NQ. 08 CV 0622 JES FOR |
i
JOIN MOTION FO CON
PDF Page 4
Case 3:08-cv-00622-W-POR Document4 Filed 06/23/2008 Page3of3
Ka.D., v. Solana Beach School District and Mary Ellen Nest (GI20546)
United States District Court, Southern District of California, Case No. 08 CV0622 JLS (POR)
JENNIFER S. CREIGHTON, STATE BAR NO. 202799
WINET, PATRICK & WEAVER
440 S. MELROSE DRIVE, SUITE 200
VISTA, CALIFORNIA 92081
TELEPHONE: (760) 758-4261
CERTIFICATE OF SERVICE
I, Vicki Asturias, declare:
Iam employed in the County of San Diego, State of California. I am over the age of 18
and not a party to the within action. My business address is 440 South Melrose Drive, Suite 200,
Vista, California 92081.
On June 23, 2008, I served the foregoing documents:
JOINT MOTION TO CONTINUE DEFENDANTS' DEADLINE TO FILE
RESPONSIVE PLEADING
on all interested persons in this action addressed as shown below and on the attached service list
which is incorporated herein as follows:
Q BY MAIL: By placing an envelope for collection and mailing following our ordinary
business practices. I am readily familiar with the firm's practice of collection and
processing of correspondence for mailing with the United States Postal Service, and that
the correspondence shall be deposited with the United States Postal Service this same day
in the ordinary course of business in a sealed envelope with first-class postage prepaid at
Vista, California.
(X) BY ELECTRONIC SERVICE: On the dated stated above, I served the documents via
CM/ECF described above on designated recipients through electronic transmission of
said documents; a certified receipt is issued to filing party acknowledging receipt by
CM/ECF's system. Once CM/ECF has served all designated recipients, proof of
electronic service is returned to the filing party.
I declare under the penalty of perjury under the laws of the State of California that the
foregoing is true and correct. I declare that I am employed in the office of a member of the bar of
this court at whose direction the service was made.
Executed on June 23, 2008, at Vista, California.
\al -Catnnag
Vicki Asturias
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