Doe et al v. County of San Mateo et al

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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JOSEPH M. GOETHALS (SBN 242889)
joe@gostlaw.com
CHARLES P. STONE (SBN 224897)
charles@gostlaw.com
DAVID G. HOLLENBERG (SBN 325408)
dave@gostlaw.com
GOETHALS & STONE, PC
330 Primrose Road, Suite 614
Burlingame, CA 94010
Telephone: (650) 218-4319
Attorneys for Plaintiffs AG DOE, et al.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
JOHN AG DOE, JOHN AP DOE, JOHN
AS DOE, JOHN JE DOE, JOHN JG3
DOE, JOHN JR DOE, JOHN KL DOE,
JOHN NZ DOE, JOHN SH DOE, JOHN
VB DOE, JOHN VE DOE, JOHN IF DOE,
AND JOHN MB DOE,
Plaintiffs,
v.
COUNTY OF SAN MATEO; STUART
FORREST; JOSE VILLEGAS; EDWARD
D. TAYLOR; SHERALYN FREITAS;
MICHAEL STAUFFER; REGINA
WILSON-HENRY; BONNIE
MACASKILL; RHONDA COLLINS;
AND DOES 1-100, INCLUSIVE,
Defendants.
Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER
EXTENDING TIME FOR PLAINTIFFS’
OPPOSITION AND DEFENDANTS’
REPLY ON DEFENDANTS’ MOTION
TO DISMISS (ECF NO. 29);
DECLARATION OF DAVID G.
HOLLENBERG IN SUPPORT
[Civil L.R. 6-2, 7-12]
Hearing: 	January 15, 2027
Time: 	10:00 a.m.
Ctrm: 	6, 17th Floor
Judge: 	Hon. Charles R. Breyer
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 1 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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Plaintiffs John AG Doe, John AP Doe, John AS Doe, John JE Doe, John JG3 Doe, John JR
Doe, John KL Doe, John NZ Doe, John SH Doe, John VB Doe, John VE Doe, John IF Doe, and John
MB Doe (“Plaintiffs”), and Defendants County of San Mateo, Stuart Forrest, Jose Villegas, Edward
D. Taylor, Sheralyn Irving Freitas, Michael Stauffer, Regina Wilson-Henry, Bonnie MacAskill, and
Rhonda Collins (collectively, the “County Defendants”), by and through their counsel of record,
submit this stipulation pursuant to Civil Local Rules 6-2 and 7-12 and Federal Rule of Civil Procedure
6(b)(1)(A), and stipulate as follows:
WHEREAS, Plaintiffs filed their Complaint on July 2, 2026 (ECF No. 1), and on July 6,
2026, the Court granted Plaintiffs leave to proceed under pseudonyms (ECF No. 6);
WHEREAS, by stipulation of the parties, the County Defendants’ deadline to respond to the
Complaint was extended to October 5, 2026 (ECF No. 27);
WHEREAS, on October 5, 2026, the County Defendants filed and served their Motion to
Dismiss Claims and Certain Plaintiffs Pursuant to Fed. R. Civ. P. 12(b)(6) (ECF No. 29) (the
“Motion”), noticed for hearing on November 20, 2026;
WHEREAS, under Civil Local Rule 7-3(a), Plaintiffs’ opposition to the Motion is currently
due October 19, 2026, and under Civil Local Rule 7-3(c), the County Defendants’ reply is due seven
days after the opposition is filed;
WHEREAS, on October 7, 2026, the Court vacated the Case Management Conference
previously set for November 13, 2026 and reset the hearing on the Motion to January 15, 2027, at
10:00 a.m. (ECF No. 30);
WHEREAS, the Motion raises issues that depend on facts specific to each of the thirteen
Plaintiffs, and as a result Plaintiffs require additional time to oppose the Motion;
WHEREAS, because the hearing on the Motion has been reset to January 15, 2027, briefing
on the Motion will be complete more than seven weeks before the hearing under the requested
schedule;
WHEREAS, the requested extension will not alter the hearing date on the Motion or any other
date fixed by Court order;
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 2 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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NOW, THEREFORE, the parties, through their undersigned counsel, hereby stipulate and
respectfully request that the Court order as follows:
1. 	Plaintiffs’ opposition to the County Defendants’ Motion to Dismiss shall be filed and
served on or before November 13, 2026.
2. 	The County Defendants’ reply in support of the Motion shall be filed and served on or
before November 20, 2026.
3. 	The hearing on the Motion shall remain set for January 15, 2027, at 10:00 a.m., in
Courtroom 6, 17th Floor, of the San Francisco Courthouse, 450 Golden Gate Avenue, San Francisco,
California.
4. 	This stipulation is entered into without prejudice to any party’s claims, defenses, or
arguments, including the arguments presented in the Motion.
IT IS SO STIPULATED.
DATED: October 15, 2026 	GOETHALS & STONE, PC
By: /s/ David G. Hollenberg
JOSEPH M. GOETHALS
CHARLES P. STONE
DAVID G. HOLLENBERG
Attorneys for Plaintiffs
DATED: October 15, 2026 	JOHN D. NIBBELIN, COUNTY COUNSEL
By: /s/ Joseph F. Charles
JOSEPH F. CHARLES, Deputy
Attorneys for Defendants County of San
Mateo, Stuart Forrest, Jose Villegas,
Edward D. Taylor, Sheralyn Irving Freitas,
Michael Stauffer, Regina Wilson-Henry,
Bonnie MacAskill, and Rhonda Collins
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 3 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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ATTESTATION
Pursuant to Civil Local Rule 5-1(i)(3), I, David G. Hollenberg, attest that concurrence in the
filing of this document has been obtained from each of the other signatories.
DATED: October 15, 2026
/s/ David G. Hollenberg
DAVID G. HOLLENBERG
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 4 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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DECLARATION OF DAVID G. HOLLENBERG
I, David G. Hollenberg, declare as follows:
1. 	I am an attorney at law licensed to practice in the State of California and admitted to
practice before this Court. I am an attorney with Goethals & Stone, PC, counsel of record for
Plaintiffs in this action. I have personal knowledge of the facts stated in this declaration and, if called
as a witness, could and would testify competently to them. I submit this declaration pursuant to Civil
Local Rule 6-2(a) in support of the foregoing stipulation.
2. 	The County Defendants’ Motion (ECF No. 29) seeks dismissal of Plaintiffs’ claims
under 42 U.S.C. § 1983 and California Civil Code § 52.1 as time-barred; dismissal of all claims
against the County of San Mateo under California Government Code § 844.6; dismissal of all claims
of three Plaintiffs on the ground that the conduct alleged occurred while each was in custody; and
dismissal of five Plaintiffs for failure to state a claim. Each of those arguments turns on facts specific
to the individual Plaintiffs, including where, when, and under what custodial status the conduct
alleged by each Plaintiff occurred, and the circumstances bearing on the accrual of each Plaintiff’s
claims.
3. 	There are thirteen Plaintiffs. Each alleges that he was sexually abused as a minor, many
years ago, while under the supervision of the San Mateo County Probation Department. Plaintiffs’
counsel requires additional time to confer with each Plaintiff individually, with the care that
conversations of this nature require, and to review the relevant records, in order to oppose the Motion.
4. 	Under the current schedule, Plaintiffs’ opposition is due October 19, 2026, which does
not allow sufficient time to complete the work described in paragraph 3. Because the Court has reset
the hearing on the Motion to January 15, 2027, the requested extension can be accommodated without
any change to the hearing date.
5. 	On October 15, 2026, I conferred with Joseph F. Charles, Deputy County Counsel,
counsel for the County Defendants, who agreed to the extension set forth in the foregoing stipulation.
6. 	The following time modifications have previously been made in this action: (a) by
stipulation of the parties, the County Defendants’ deadline to respond to the Complaint was extended
to October 5, 2026 (ECF No. 27); and (b) on October 7, 2026, the Court vacated the Case
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 5 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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Management Conference previously set for November 13, 2026 and reset the hearing on the Motion
from November 20, 2026, to January 15, 2027 (ECF No. 30). There have been no other time
modifications in this action.
7. 	The requested extension will not affect the January 15, 2027 hearing date or any other
date fixed by Court order. Under the proposed schedule, briefing on the Motion will be complete on
November 20, 2026, more than seven weeks before the hearing. No Case Management Conference is
currently set. No trial date or other case deadlines have been set.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed on October 15, 2026, at Burlingame, California.
/s/ David G. Hollenberg
DAVID G. HOLLENBERG
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 6 of 7

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Case No. 3:26-cv-06838-CRB
STIPULATION AND PROPOSED ORDER EXTENDING TIME FOR OPPOSITION AND REPLY ON MOTION
TO DISMISS; HOLLENBERG DECLARATION
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PROPOSED ORDER
Pursuant to the foregoing stipulation of the parties, and good cause appearing, IT IS HEREBY
ORDERED as follows:
1. 	Plaintiffs’ opposition to Defendants’ Motion to Dismiss (ECF No. 29) shall be filed on
or before November 13, 2026.
2. 	Defendants’ reply in support of the Motion shall be filed on or before November 20,
2026.
3. 	The hearing on the Motion to Dismiss remains set for January 15, 2027, at 10:00 a.m.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATED: ______________________ 	______________________________________
HON. CHARLES R. BREYER
United States District Judge
October 15, 2026
Case 3:26-cv-06838-CRB Document 32 Filed 10/15/26 Page 7 of 7