Daniels Sharpsmart, Inc. v. Smith, et al.

Filing 17

JOINT STIPULATION EXTENDING TIME FOR STATE DEFENDANTS TO RESPOND TO PLAINTIFF'S MOTION FOR PRELIMINARY INJUNCTION AND ORDER THEREON signed by Chief Judge Lawrence J. O'Neill on May 23, 2017. (Munoz, I)

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XAVIER BECERRA, State Bar No. 118517
Attorney General of California
ISMAEL A. CASTRO, State Bar No. 85452
Supervising Deputy Attorney General
RENU R. GEORGE, State Bar No. 262310
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 State Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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DANIEL SHARPSMART, INC.,

1:17-cv-00403-LJO-SAB

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v.
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Plaintiff, JOINT STIPULATION EXTENDING
TIME FOR STATE DEFENDANTS TO
RESPOND TO PLAINTIFF’S MOTION
FOR PRELIMINARY INJUNCTION
AND ORDER THEREON

KAREN SMITH, ET AL.,

9, 6th Floor
The Honorable Stanley A.
Boone
Trial Date:
None Set
Action Filed: March 20, 2017

Courtroom:
Defendant. Judge:

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JOINT STIPULATION EXTENDING TIME FOR STATE DEFENDANTS TO RESPOND
TO PLAINTIFF’S PRELIMINARY INJUNCTION MOTION

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Pursuant to Local Rule 144(a), Plaintiff Daniels Sharpsmart, Inc. and Defendants Karen

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Smith, Richard Pilorin, Alison Dabney, and Ginger Hilton (collectively, “State Defendants”), by

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and through their respective counsel, hereby stipulate to grant State Defendants additional time to

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respond to Plaintiff’s Motion for Preliminary Injunction as set forth below:

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Joint Stipulation to Extend Time to Respond to Plaintiff’s Motion for Preliminary Injunction (1:17-cv-00403-LJOSAB)

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WHEREAS, Plaintiff filed a Motion for Preliminary Injunction on May 9, 2017, set for
hearing on June 8, 2017;

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WHEREAS, pursuant to Local Rule 230© State Defendants’ opposition to Plaintiff’s

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Motion to Preliminary Injunction is due May 25, 2017 and Plaintiff’s Rely is due on June 1,

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2017;

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WHEREAS, Deputy Attorney General Renuka George, counsel for State Defendants had a

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medical emergency resulting from a car accident on May 18, 2017 and therefore State Defendants

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require additional time in which to respond to Plaintiff’s Motion for Preliminary Injunction;

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WHEREAS, in the interest of justice and in an effort to enhance judicial efficiency and

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preserve resources, Plaintiff agrees to grant State Defendants seven (7) days additional time in

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which to respond to the Motion for Preliminary Injunction and the parties agree to move the June

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8, 2017 hearing an additional seven (7) days to allow Plaintiff adequate time to Reply to State

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Defendants’ Opposition;

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WHEREAS, the extension sought will not alter any other date of any event or deadline
already fixed by Court Order.

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NOW THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE that the time

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in which State Defendants shall respond to Plaintiff’s Motion for Preliminary Injunction in this

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action shall be continued seven (7) in this action until June 1, 2017 and the hearing shall be

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continued until June 15, 2017.

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Joint Stipulation to Extend Time to Respond to Plaintiff’s Motion for Preliminary Injunction (1:17-cv-00403-LJOSAB)

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Dated: May 23, 2017

Respectfully submitted,

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XAVIER BECERRA
Attorney General of California
ISMAEL A. CASTRO
Supervising Deputy Attorney General

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/s/ Julia Jackson
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JULIA JACKSON
Deputy Attorney General
Attorneys for State Defendants

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/s/ Jason Levin

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JASON LEVIN
Steptoe & Johnson LLP
Attorney for Plaintiff Daniels Sharpsmart

Dated: May 23, 2017

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SA2017106433
12698010.doc

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Joint Stipulation to Extend Time to Respond to Plaintiff’s Motion for Preliminary Injunction (1:17-cv-00403-LJOSAB)

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ORDER
Based on the Parties’ above Joint Stipulation, IT IS HEREBY ORDERED THAT the State

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Defendants’ time to serve and file a response to Plaintiff’s Motion for Preliminary Injunction in

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the above entitled action shall be extended from May 25, 2017 to June 1, 2017 pursuant to Local

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Rule 144(a). The hearing on the motion shall be continued until June 15, 2017.

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IT IS SO ORDERED.
Dated:

/s/ Lawrence J. O’Neill _____

May 23, 2017

UNITED STATES CHIEF DISTRICT JUDGE
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Joint Stipulation to Extend Time to Respond to Plaintiff’s Motion for Preliminary Injunction (1:17-cv-00403-LJOSAB)