Edison v. United States of America et al

Filing 112

ORDER GRANTING 111 Stipulation to Extend Time for Defendants to Respond to the Amended Complaint, signed by Magistrate Judge Jennifer L. Thurston on 12/22/2016. (Hall, S)

1 Ian Wallach, SBN 237849
Jason K. Feldman SBN 213386
2 FELDMAN & WALLACH
606 Venice Blvd., Suite C
3
Venice, CA 90291
4 Telephone: [phone]
Fax: [phone]
5 [e-mail]
[e-mail]
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Attorneys for Plaintiffs
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PHILLIP A. TALBERT
United States Attorney
ALYSON A. BERG
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
United States of America

8 Raymond P. Boucher, SBN 115364
[e-mail]
9 Hermez Moreno, SBN 72009
10 [e-mail]
Milin Chun, SBN 262674
11 [e-mail]
Brian M. Bush, SBN 294713
12 [e-mail]
BOUCHER LLP
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21600 Oxnard Street, Suite 600
14 Woodland Hills, CA 91367-4903
Tel: [phone]
15 Fax: [phone]

Susan E. Coleman (SBN 171832)
Kristina Gruenberg (SBN 268188)
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Defendant
Manangement & Training Corporation

16 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
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21 GREGORY EDISON,
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Case No. 1:12-cv-02026-AWI-JLT

Plaintiff,
JOINT STIPULATION TO EXTEND
TIME FOR DEFENDANTS TO
RESPOND TO THE AMENDED
COMPLAINTS AND [PROPOSED]
ORDER

v.

24 UNITED STATES OF AMERICA; THE GEO
GROUP, INC.; MANAGEMENT AND
25 TRAINING CORPORATION,
26

(Doc. 111)

Defendants.

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1
JOINT STIPULATION AND [PROPOSED] ORDER

1
RICHARD NUWINTORE,

Case No. 1:13-cv-00967-AWI-JLT

2
Plaintiff,
3
v.
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UNITED STATES OF AMERICA;
5 MANAGEMENT AND TRAINING
CORPORATION,
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Defendants.

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8

LOUIS C. DOMINGO,

9

Case No. 1:15-cv-00284-AWI-JLT

Plaintiff,

10

v.

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MANAGEMENT & TRAINING
12 CORPORATION; and JOHN DOES 1-9,
13

Defendants.

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Defendants United States and Management and Training Corporation (hereafter known as

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16 “Defendants”), and Plaintiffs Gregory Edison, Richard Nuwintore, and Louis Domingo (hereafter
17 known as “Plaintiffs”), by and through their respective counsel, stipulate as follows:
On December 12, 2016, Plaintiffs filed their Amended Complaints1 against the

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19 Defendants, the United States and its contractor, Management & Training Corporation (MTC).
20 Pursuant to the court’s orders, the United States shall file responsive pleadings by January 3, 2017
21 and MTC need not file responsive pleadings. (ECF Nos. 107, 113, 55).
Due to a pre-planned vacation, federal holidays on December 26, 2016 and January 2,

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23 2017, and to allow the parties to attempt to avoid a motion as the initial response, good cause
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1

Plaintiff Gregory Edison filed a First Amended Complaint (ECF No. 110), Plaintiff Richard
Nuwintore filed a Third Amended Complaint (ECF No. 117), and Plaintiff Louis Domingo filed a
28 Second Amended Complaint (ECF No. 58).
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2
JOINT STIPULATION AND [PROPOSED] ORDER

1 exists to continue the response date for the United States from January 3, 2017 to and including
2 February 2, 2017.2
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Accordingly, Plaintiffs and Defendants hereby stipulate and agree as follows:

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1. The deadline for the United States to respond to the Amended Complaints shall be

5 extended up to and including February 2, 2017.
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2. This stipulation will not alter the date of any event or any deadline already fixed by

7 Court order.
8 DATED: December 21, 2016

FELDMAN & WALLACH, LLP

9

12

(As authorized 12/21/2016)
/s/ Jason Feldman
IAN WALLACH
JASON FELDMAN
Attorneys for Plaintiffs, Gregory Edison, Louis C.
Domingo, Richard Nuwintore

13 DATED: December 21, 2016

BURKE, WILLIAMS & SORENSEN, LLP

14

(As authorized 12/21/2016)
/s/ Kristina Gruenberg
SUSAN E. COLEMAN
KRISTINA GRUENBERG
Attorneys for Defendant,
Management & Training Corporation

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11

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16
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18 DATED: December 21, 2016
19

PHILLIP A. TALBERT
United States Attorney
/s/ Alyson A. Berg
ALYSON A. BERG
Assistant United States Attorney
Attorneys for Defendant,
United States of America

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2

MTC does not oppose the agreement between plaintiffs and the United States regarding the date
28 for the United States to respond to the amended complaints.
3
JOINT STIPULATION AND [PROPOSED] ORDER

1
2

[PROPOSED] ORDER
Having reviewed the stipulation submitted by the parties and for good cause showing, the

3 court hereby orders as follows:
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1. The deadline for the United States to respond to the Amended Complaints shall be

5 extended up to and including February 2, 2017.
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2. This stipulation will not alter the date of any other event or any deadline already fixed

7 by Court order.
8
9 IT IS SO ORDERED.
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Dated:

December 22, 2016

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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JOINT STIPULATION AND [PROPOSED] ORDER