Rivera-Martinez et al v. Kern County et al

Filing 23

ORDER GRANTING Defendant Dr. Hayden to file his amended answer within 5 days, signed by Magistrate Judge Jennifer L. Thurston on 8/19/2016. (Kusamura, W)

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Andrew R. Weiss #95567
Carol A. O’Neil #71282
WEISS MARTIN SALINAS & HEARST
A Professional Corporation
7108 North Fresno Street, Suite 250
Fresno, California 93720
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant Philip Hyden, M.D.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CYNTHIA RIVERA-MARTINEZ and
ARTURO MARTINEZ,

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Plaintiffs,
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vs.
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KERN COUNTY; KERN COUNTY
DEPARTMENT OF HUMAN RESOURCES; )
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SOCIAL WORKER STEPHANIE MEEK,
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individually; PHILIP HYDEN, M.D.,
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individually; and DOES 1 through 100,
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inclusive,
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Defendants.
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Case No. 1:16-CV-00062---JLT
WRITTEN CONSENT OF PLAINTIFFS
CYNTHIA RIVERA-MARTINEZ AND
ARTURO MARTINEZ AND CODEFENDANTS KERN COUNTY, KERN
COUNTY DEPARTMENT OF HUMAN
RESOURCES AND SOCIAL WORKER
STEPHANIE MEEK TO THE FILING OF
DEFENDANT PHILIP HYDEN, M.D’S
(PROPOSED) FIRST AMENDED
ANSWER TO PLAINTIFFS’ FIRST
AMENDED COMPLAINT AND COURT
ORDER THEREON
(Doc. 22)

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Pursuant to Federal Rules of Civil Procedure, Rule 15 (2) which allows for amendment of

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a party’s pleadings before trial with the other parties’ written consent and for the sake of

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preserving precious judicial resources that would be consumed if a motion for leave to amend

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were made, Defendant, PHILIP HYDEN (“Dr. Hyden”), respectfully submits this stipulation in
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WRITTEN CONSENT TO PERMIT FILING OF DEFENDANT PHILIP HYDEN, M.D.’S FIRST AMENDED ANSWER TO
PLAINTIFFS’ FIRST AMENDED COMPLAINT AND ORDER THEREON

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which Plaintiffs CYNTHIA RIVERA-MARTINEZ and ARTURO MARTINEZ and Co-

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Defendants KERN COUNTY, KERN COUNTY DEPARTMENT OF HUMAN RESOURCES

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and SOCIAL WORKER STEPHANIE MEEK, by and through their respective counsel of

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record, hereby consent in writing to the filing of Dr. Hyden’s (Proposed) First Amended Answer

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to Plaintiff’s First Amended Complaint, a true and correct copy of which is attached hereto as

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Exhibit “A.”
Dated: August 18, 2016

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LACK LAW GROUP, APC

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By:
/s/ Rebecca D. Lack (electronic signature
use authorized on August 17, 2016)
Rebecca D. Lack
Attorneys for Plaintiffs
Cynthia Rivera-Martinez and
Arturo Martinez

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Dated: August 18, 2016

COUNTY OF KERN, COUNTY COUNSEL

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By:
/s/ Kathleen Rivera (electronic signature
use authorized on August 17, 2016)
Theresa A. Goldner, County Counsel
By: Kathleen Rivera, Deputy
Attorneys for Defendants
Kern County, Kern County Department of
Human Services and Social Worker
Stephanie Meek

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Dr. Hyden requests that this court issue the order below based on the above

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written consents of the respective counsel for Plaintiffs and Co-Defendants. Attached hereto as

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Exhibit B are true and correct copies of emails in which attorneys, Rebecca Lack and Kathleen

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Rivera, have authorized the use of their electronic signatures on this written consent

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.

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///

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///

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WRITTEN CONSENT TO PERMIT FILING OF DEFENDANT PHILIP HYDEN, M.D.’S FIRST AMENDED ANSWER TO
PLAINTIFFS’ FIRST AMENDED COMPLAINT AND ORDER THEREON

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Dated: August 19, 2016

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WEISS MARTIN SALINAS & HEARST
A Professional Corporation

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By:

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/s/ Carol A. O’Neil
Andrew R. Weiss
Carol A. O’Neil
Attorneys for Defendant
Philip Hyden, M.D.

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ORDER

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Based on the stipulation of the parties, the Court ORDERS that defendant, Dr. Hyden,
may file his first amended answer within five days.

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IT IS SO ORDERED.
Dated:

August 19, 2016

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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WRITTEN CONSENT TO PERMIT FILING OF DEFENDANT PHILIP HYDEN, M.D.’S FIRST AMENDED ANSWER TO
PLAINTIFFS’ FIRST AMENDED COMPLAINT AND ORDER THEREON