Opinion
Case No.: 12-cv-01441-JST
05-13-2013
KAREN TATE, Plaintiff, v. STATE OF CALIFORNIA, CALIFORNIA DEPARTMENT OF CORRECTIONS AND REHABILITATION; TIMOTHY REYNOLDS; and DOES 1 to 100, Defendants.
RESPECTFULLY SUBMITTED, LAW OFFICES OF BONNER & BONNER A. Cabral Bonner Attorney for Plaintiff RESPECTFULLY SUBMITTED KAMALA D. HARRIS Attorney General of California MIGUEL A. NERI Supervising Deputy Attorney General DAVID PAI Deputy Attorney General Attorneys for Defendants California Department of Corrections and Rehabilitation and Timothy Reynolds
CHARLES A. BONNER, ESQ. SB# 85413
A. CABRAL BONNER, ESQ. SB# 247528
LAW OFFICES OF CHARLES A. BONNER
475 GATE FIVE RD, SUITE 212
SAUSALITO, CA 94965
TEL: (415) 331-3070
FAX: (415) 331-2738
cbonner799@aol.com
cabral@bonnerlaw.com
ATTORNEYS FOR PLAINTIFF
STIPULATION TO FILE AMENDED
COMPLAINT
AND [PROPOSED] ORDER
IT IS HEREBY STIPULATED AND AGREED BY THE PARTIES, through their respective attorneys of record, A. CABRAL BONNER of THE LAW OFFICES OF BONNER & BONNER, attorney for Plaintiff, and David Pai, Deputy Attorney General, attorney for all Defendants, as indicated by their signatures below, to grant Plaintiff leave to file an Amended Complaint to incorporate new allegations which took place after Plaintiff filed her initial complaint.
Good cause exists for the amendment because the new allegations included in the Amended Complaint occurred after the filing of the Complaint, but generally arise out of a common nucleus of operative fact as the original complaint. A copy of Plaintiff s Amended Complaint is attached as Exhibit A. Modified portions are italicized.
RESPECTFULLY SUBMITTED,
LAW OFFICES OF BONNER & BONNER
________________
A. Cabral Bonner
Attorney for Plaintiff
RESPECTFULLY SUBMITTED
KAMALA D. HARRIS
Attorney General of California
MIGUEL A. NERI
Supervising Deputy Attorney General
________________
DAVID PAI
Deputy Attorney General
Attorneys for Defendants California
Department of Corrections and
Rehabilitation and Timothy Reynolds
[PROPOSED] ORDER
IT IS SO ORDERED, PLAINTIFFS MAY FILE AN AMENDED COMPLAINT.
DISTRICT COURT JUDGE
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