Simmons v. Rodriguez, et al.

Filing 29

STIPULATION and ORDER signed by District Judge John A. Mendez on 7/8/16: Defendants shall have until July 22, 2016 to respond to the amended complaint. (Kaminski, H)

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
TRACY S. HENDRICKSON, State Bar No. 155081
Supervising Deputy Attorney General
JON S. ALLIN, State Bar No. 155069
Supervising Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
Hall and Rodriguez

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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FRESNO DIVISION

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RACHEL SIMMONS,

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v.

1:15-cv-00818-JAM-EPG
Plaintiff, STIPULATION FOR SECOND
EXTENSION OF TIME FOR
DEFENDANTS TO FILE RESPONSE TO
FIRST AMENDED COMPLAINT

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CORRECTIONAL OFFICER
RODRIGUEZ, et al.,

(No appearance requested.)
Judge:
Defendants. Trial Date:
Action Filed:

Hon. John A. Mendez
Not Set
May 28, 2015

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1. The parties stipulate under Local Rule 144(a) to a fourteen-day extension of time for
Defendants Hall and Rodriguez to respond to the first amended complaint.
2. Good cause to extend time exists because counsel are meeting and conferring regarding

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the substance and potential resolution of Defendants’ anticipated motion to dismiss as required by

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the Court’s Order re Filing Requirements for Cases Assigned to Judge Mendez (ECF No. 14-1).

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Counsel have on multiple occasions discussed and exchanged correspondence regarding the

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claims and defenses in this action and in Plaintiff’s parallel state-court action, Simmons v. CO
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Stip. Ext. Time Resp. Plead. (1:15-cv-0081-JAM-EPG)

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Rodriguez, et al., No. 15C-0113, (Kings Co. Super. Ct. filed May 29, 2015), and have scheduled a

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further telephone conference for Monday, July 11, 2016.

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3. There has been one previous extension of time of twenty-eight days. (ECF No. 27.)

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4. Under this stipulation, Defendants would have until July 22, 2016 to respond to the

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amended complaint.

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Dated: July 8, 2016

/s/ Julia M. Young
(as authorized on July 8, 2016)
JULIA M. YOUNG
Attorney for Plaintiff
Rachel Simmons

Dated: July 8, 2016

KAMALA D. HARRIS
Attorney General of California
TRACY S. HENDRICKSON
Supervising Deputy Attorney General

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/s/ Jon S. Allin
_____________________________
JON S. ALLIN
Supervising Deputy Attorney General
Attorneys for Defendants
Hall and Rodriguez

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IT IS SO ORDERED.

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Dated: July 8, 2016

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/s/ John A. Mendez
John A. Mendez
United States District Judge

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SA2015301245
12337903.doc

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Stip. Ext. Time Resp. Plead. (1:15-cv-0081-JAM-EPG)