McKeon et al v. Central Valley Community Sports Foundation et al

Filing 55

STIPULATION and ORDER to Extend Deadline for Motion for Leave to Amend Plaintiff's Second Amended Complaint signed by Magistrate Judge Barbara A. McAuliffe on 2/21/2019. (Sant Agata, S)

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RACHELLE TAYLOR GOLDEN 295385
HATMAKER LAW GROUP
A Professional Corporation
7522 N. Colonial Avenue, Suite 105
Fresno, California 93711
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs: MEGAN MCKEON, TINA NEAL, and
LAILA NEAL

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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* * *

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MEGAN MCKEON; LAILA NEAL, A
MINOR BY AND THROUGH HER
GUARDIAN AD LITEM, TINA NEAL;
and TINA NEAL,

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Plaintiffs,
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vs.
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CENTRAL VALLEY COMMUNITY
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SPORTS FOUNDATION, a Non-Profit
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Corporation, dba GATEWAY ICE
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CENTER; and JEFF BLAIR, an individual; )
and DOES 1 through 50, Inclusive,
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Defendants.
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NO. 1:18-cv-00358-DAD-BAM
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR MOTION
FOR LEAVE TO AMEND
PLAINTIFFS’ SECOND AMENDED
COMPLAINT

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IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs, MEGAN

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MCKEON, LAILA NEAL by and through her Guardian Ad Litem, Tina Neal, and TINA NEAL

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and Defendants, CENTRAL VALLEY COMMUNITY SPORTS FOUNDATION and JEFF

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BLAIR (“Defendants”), through their respective counsel of record, that the Parties mutually

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agree to extend the deadline as specified in the Court’s December 7, 2018 Order “Granting in

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Part and Denying in Part Plaintiffs’ Motion for Leave to File a Second Amended Complaint.”
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STIPULATION TO EXTEND DEADLINE

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(Document 45.)

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Plaintiffs’ served Request for Production of Documents, Set One, on December 19, 2018,

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and after Defendants’ responses were received on December 28, 2018, counsel for the Parties

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met and conferred regarding Defendants’ responses on February 7, 2019.

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Defendants has requested additional time to provide supplemental responses, rendering the

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supplemental responses due on March 15, 2019. Therefore, the Parties wish to extend the

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deadline for Plaintiffs’ Motion for Leave to Amend the Second Amended Complaint from

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February 15, 2019 to March 29, 2019. It was also agreed that should the Court wish to contact

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the Parties to discuss this Stipulation, counsel for the Parties are amiable.

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DATED: February 13, 2019

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HATMAKER LAW GROUP
A Professional Corporation
By:

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Counsel for

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/s/ Rachelle Taylor Golden__________
RACHELLE TAYLOR GOLDEN
Attorney for Plaintiffs, MEGAN
MCKEON, TINA NEAL and
LAILA NEAL

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DATED: February 13, 2019

COLEMAN & HOROWITT, LP

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By:

/s/ Keith White
DAVID J. WEILAND
KEITH WHITE
Attorney for Defendants, CENTRAL
VALLEY COMMUNITY SPORTS
FOUNDATION and JEFF BLAIR

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STIPULATION TO EXTEND DEADLINE

ORDER

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Pursuant to the parties’ stipulation, and good cause appearing, IT IS HEREBY

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ORDERED that Plaintiffs MEGAN MCKEON, TINA NEAL and LAILA NEAL shall have up

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to and including March 29, 2019, to file a Motion for Leave to Amend the Second Amended

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Complaint. Fed. R. Civ. P. 16(b)(4). All other deadlines in the Scheduling Order issued on

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August 8, 2018, shall remain in effect. (Doc. 34.)

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IT IS SO ORDERED.
Dated:

February 21, 2019

/s/ Barbara

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO EXTEND DEADLINE

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