Klomp et al v. Frost
Filing
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STIPULATION and ORDER TO ENLARGE BRIEFING SCHEDULE ON PLAINTIFFS' MOTION FOR REMAND AND AMENDED MOTION FOR REMAND. Order signed by Magistrate Judge Sheila K. Oberto on 1/28/2025. (Deputy Clerk WAK)
1 Jason S. Roberts, Esq. (SBN: 221978)
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Preetpal S. Toor, Esq. (SBN: 325663)
RESNICK & LOUIS, P.C.
9891 Irvine Center Drive, Suite 200
Irvine, CA 92618
Telephone/Facsimile: (909) 457-7402
Email: jsroberts@rlattorneys.com;
ptoor@rlattorneys.com
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Attorneys for Defendant
DAVID B. FROST
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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DENNIS A. KLOMP, individually and as
successor in interest of NEVA MARLENE
KLOMP, decedent; DARYL KLOMP,
individually and as successor in interest of
NEVA MARLINE KLOMP, decedent;
NATALIE KLOMP-WOODS, individually
and as successor in interest of NEVA
MARLENE KLOMP, decedent,
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Plaintiffs,
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Case No.: 1:24-cv-01507-JLT-SKO
STIPULATION TO ENLARGE
BRIEFING SCHEDULE ON
PLAINTIFFS’ MOTION FOR
REMAND AND AMENDED
MOTION FOR REMAND [DOC.
NOS. 4 AND 9]; ORDER
(Doc. 12)
v.
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DAVID B. FROST, and DOES 1-50,
inclusive,
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Defendants.
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IT IS HEREBY STIPULATED AND AGREED by Plaintiffs DENNIS A. KLOMP,
individually and as successor in interest of NEVA MARLENE KLOMP, decedent; DARYL
KLOMP, individually and as successor in interest of NEVA MARLINE KLOMP, decedent;
NATALIE KLOMP-WOODS, individually and as successor in interest of NEVA MARLENE
KLOMP, and Defendant DAVID B. FROST by and through their counsel of record herein, as
follows:
STIPULATION TO ENLARGE BRIEFING SCHEDULE ON MOTION TO REMAND
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WHEREAS Plaintiffs filed a Motion for Remand on January 9, 2025 (Doc. No. 4), and
2 an Amended Motion for Remand on January 14, 2025 (Doc. No. 9), (collectively, the
3 “Motion”) which is pending before this Court;
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WHEREAS counsel for Plaintiffs and Defendants are meeting and conferring regarding
5 this Court’s order of January 13, 2025, (Doc. No. 8) that requires the parties to consider consent
6 to the magistrate judge for all purposes and/or for purposes of the Motion and to submit consent
7 forms within 30-days of the Court’s order;
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WHEREAS Defendant requires additional time to prepare and submit his opposition to
9 the pending Motion due to staffing issues caused by the ongoing fires in Southern California
10 and the press of business;
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WHEREAS the parties respectfully request that the deadline for Defendant’s opposition
12 be extended to February 14, 2025, or as otherwise set by the Court should the parties hereafter
13 consent to magistrate judge jurisdiction; and
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WHEREAS the parties respectfully request that the deadline for Plaintiffs reply be
15 extended to February 28, 2025, or as otherwise set by the Court should the parties hereafter
16 consent to magistrate judge jurisdiction.
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STIPULATION TO ENLARGE BRIEFING SCHEDULE ON MOTION TO REMAND
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STIPULATION
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IT IS HEREBY STIPULATED AND AGREED by and between the undersigned
3 parties, via counsel of record, subject to approval and entry by the Court, that:
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1.
Defendant’s opposition to Plaintiff’s Motion to Remand is to be filed on or before
5 February 14, 2025; and
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2.
Plaintiffs’ reply to Defendant’s opposition to the Motion is to be filed on or before
7 February 28, 2025.
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9 DATED: January 28, 2025
RESNICK & LOUIS, P.C.
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/s/Jason S. Roberts
Jason S. Roberts
Preetpal S. Toor
Attorneys for Defendant
DAVID B. FROST
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15 DATED: January 24, 2025
NUNES LAW, INC.
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s/ Frank Nunes
Frank Nunes, Esq.
Attorneys for Plaintiffs, DENNIS A. KLOMP,
individually and as successor in interest of NEVA
MARLENE KLOMP, decedent; DARYL KLOMP,
individually and as successor in interest of NEVA
MARLENE KLOMP, decedent; NATALIE
KLOMP-WOODS, individually and as successor in
interest of NEVA MARLENE KLOMP, decedent
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ORDER
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Before the Court is a stipulation by Plaintiffs Dennis A. Klomp, Daryl Klomp, and Natalie
26 Klomp-Woods (“Plaintiffs”) and Defendant David B. Frost (“Defendant”) to continue Defendant’s
27 deadline to file its opposition to Plaintiffs’ Amended Motion to Remand (Doc. 9) to February 14,
28 2025, and to extend the deadline for Plaintiffs to file their reply to Defendant’s opposition to
STIPULATION TO ENLARGE BRIEFING SCHEDULE ON MOTION TO REMAND
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1 February 28, 2025. (Doc. 12.)
The Court, having considered the stipulation and finding good cause, HEREBY ORDERS AS
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1. The deadline for Defendant to file its opposition to Plaintiffs’ Amended Motion to
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Remand is continued to February 14, 2025;
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2. The deadline for Plaintiff to file its reply to Defendant’s opposition is continued to
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February 28, 2025; and
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3. The hearing on Plaintiff’s Amended Motion to Remand shall remain vacated and shall be
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reset only if the Court determines a hearing is needed.
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IT IS SO ORDERED.
12 Dated:
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January 28, 2025
/s/ Sheila K. Oberto
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UNITED STATES MAGISTRATE JUDGE
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STIPULATION TO ENLARGE BRIEFING SCHEDULE ON MOTION TO REMAND
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