Mitchell v. Jeffries et al

Filing 13

STIPULATION and ORDER 12 to Extend Time to Respond to Defendant's Answer, signed by Magistrate Judge Jennifer L. Thurston on 3/13/2018. (Hall, S)

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Peter Bibring (SBN 223981)
[e-mail]
Adrienna Wong (SBN 282026)
[e-mail]
ACLU FOUNDATION
OF SOUTHERN CALIFORNIA
1313 West 8th Street
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]
Novella Coleman (SBN 281632)
[e-mail]
Linda Lye (SBN 215584)
[e-mail]
ACLU FOUNDATION
OF NORTHERN CALIFORNIA
39 Drumm Street
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF CALIFORNIA

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ROBERT MITCHELL, an individual,

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Plaintiff,
v.
RONNIE JEFFRIES, in his individual
capacity; JOHN BISHOP, in his
individual capacity; FNU SHERMAN,
in his individual capacity; and CITY of
BAKERSFIELD;

CASE NO: 1:18-cv-00146-LJO-JLT
JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND
TIME TO RESPOND TO
DEFENDANTS' ANSWER
(Doc. 12)

Defendants.

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STIPULATION TO EXTEND TIME TO RESPOND TO DEFENDANTS’ ANSWER

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Plaintiff and Defendants, through their respective counsel, hereby stipulate
to extending Plaintiff’s time to respond to Defendants’ Answer to March 21, 2018.
Good cause exists for the stipulated extension. Earlier this week, the parties

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met and conferred on the potential filing of a Motion to Strike Affirmative

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Defenses by Plaintiff, or an Amended Answer and/or Motion to Dismiss by

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Defendants. The stipulated extension will give Defendants’ counsel the additional

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time they require to consider Plaintiff’s contemplated Motion to Strike. The

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extension will thus serve the interests of efficiency and judicial economy by

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permitting the parties an opportunity to reach agreement on how to proceed in a

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manner that will enable them to effectively and economically approach discovery

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and future litigation of this case.

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Respectfully submitted,

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DATED: March 8, 2018

ACLU FOUNDATION OF
SOUTHERN CALIFORNIA

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By:

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/s/ Adrienna Wong
Adrienna Wong

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Attorney for Plaintiff
ROBERT MITCHELL

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DATED: March 8, 2018

MARDEROSIAN & COHEN
By:

/s/ Heather S. Cohen
Heather S. Cohen

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Attorney for Defendants
RONNIE JEFFRIES, JOHN BISHOP,
CHARLES SHERMAN, and CITY OF
BAKERSFIELD

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STIPULATION TO EXTEND TIME TO RESPOND TO DEFENDANTS’ ANSWER

[PROPOSED] ORDER

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Pursuant to the parties’ stipulation, the deadline for Plaintiff to file a motion to strike
pursuant to Federal Rule of Civil Procedure 12(f) is extended to March 21, 2018.

IT IS SO ORDERED.

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Dated:

March 12, 2018

/s/ Jennifer L. Thurston
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO EXTEND TIME TO RESPOND TO DEFENDANTS’ ANSWER