San Joaquin Valley Railroad Co. v. SA Recycling LLC

Filing 6

STIPULATION and ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT (LOCAL RULE 144(a)) signed by Magistrate Judge Sheila K. Oberto on 9/25/2024. Having reviewed the Joint Stipulation for an Extension of Time to Respond to Complaint (the "Joint Stipulation") (Doc. #5 ) and finding good cause, the Court hereby orders that Defendant SA Recycling LLC ("Defendant")'s deadline to respond to Plaintiff San Joaquin Valley Railroad Co. ("Plaintiff")'s Complaint shall be extended to October 28, 2024. (Lopez Amador, Corina)

1
2
3
4
5
6
7
8
9
10
11

John A. Conkle (SB# 117849)
[e-mail]
Evan Pitchford (SB# 256536)
[e-mail]
THOMPSON HINE LLP
3130 Wilshire Boulevard, Suite 500
Santa Monica, California 90403-2351
Phone: [phone] • Fax: [phone]
Attorneys for Defendant
SA Recycling LLC
Jerome D. Rybarczyk (SB# 103982)
SIMS LAW FIRM, LLP
19712 MacArthur Boulevard, Suite 1120
Irvine, California 92612
Phone: [phone] • Fax: [phone]
Attorneys for Plaintiff
San Joaquin Valley Railroad Co.

12

UNITED STATES DISTRICT COURT

13

FOR THE EASTERN DISTRICT OF CALIFORNIA

14
15
16
17

SAN JOAQUIN VALLEY
RAILROAD CO.,
Plaintiff,

18
19

Case No. 1:24-cv-01042-KES-SKO
STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
(LOCAL RULE 144(a))

vs.

20

SA RECYCLING LLC,

21

Defendant.
_____________________________________/

Complaint Served: Sept. 9, 2024
Current Response Date: Sept. 30, 2024
New Response Date: Oct. 28, 2024
Hon Kirk E. Sherriff
Presiding Judge

22
23
24
25
26
27
28

TO THE COURT, THE PARTIES, AND ATTORNEYS OF RECORD:
Plaintiff San Joaquin Valley Railroad Co. (“SJVR”) on the one hand, and Defendant SA
Recycling LLC (“SA Recycling”), on the other hand, by and through their respective counsel of
record, hereby stipulate to an extension of time for SA Recycling to respond to SJVR’s
Complaint, as follows:
1. On August 30, 2024, SJVR filed the instant action in this Court;

1

2. On September 9, 2024, SJVR served the Complaint on SA Recycling, and pursuant to

2

such service, SA Recycling’s response to the Complaint was initially due on September 30, 2024;

3

3. On September 17, 2024, counsel for SJVR and SA Recycling conferred via email and

4

agreed, pursuant to Local Rule 144(a), to extend SA Recycling’s time to respond to the

5

Complaint to October 28, 2024, which in compliance with Local Rule 144(a) is 28 days from SA

6

Recycling’s initial response deadline; and

7

4. No previous extensions have been sought or granted.

8

THEREFORE, IT IS HEREBY STIPULATED AND AGREED that SA Recycling’s

9

deadline for responding to SJVR’s Complaint shall be extended by 28 days, up to and including

10

October 28, 2024.

11
Dated: September 23, 2024

12

John A. Conkle
Evan Pitchford, members of
THOMPSON HINE LLP

13

By:/s/ Evan Pitchford
Evan Pitchford
Attorneys for Defendant
SA Recycling LLC

14
15
16
Dated: September 23, 2024

17

SIMS LAW FIRM, LLP
By: /s/ Jerome D. Rybarczyk1
Jerome D. Rybarczyk
Attorneys for Plaintiff
San Joaquin Valley Railroad Co.

18
19
20

ORDER

21

Having reviewed the Joint Stipulation for an Extension of Time to Respond to Complaint

22

(the “Joint Stipulation”) (Doc. 5) and finding good cause, the Court hereby orders that Defendant

23

SA Recycling LLC (“Defendant”)’s deadline to respond to Plaintiff San Joaquin Valley Railroad

24

Co. (“Plaintiff”)’s Complaint shall be extended to October 28, 2024.

25
26

IT IS SO ORDERED.

27

Dated:

/s/ Sheila K. Oberto

September 25, 2024

.

UNITED STATES MAGISTRATE JUDGE

28
2

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3