Brodheim v Welch, et al

Filing 80

STIPULATION and ORDER signed by Magistrate Judge Gregory G. Hollows on 11/9/2013 and agreed by the parties that defendants shall file their response to the sixth amended complaint on or before 11/18/2013. (Yin, K)

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
CHRISTOPHER J. BECKER, State Bar No. 230529
Supervising Deputy Attorney General
DIANA ESQUIVEL, State Bar No. 202954
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Defendants DiNinni, Kenneally,
Moore, Perez, Schwarzenegger, and their successors
in office

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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MICHAEL BRODHEIM,

No. 2:05-cv-1512-LKK-GGH (PC)

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v.
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Plaintiff, STIPULATION AND ORDER FOR TENDAY EXTENSION FOR DEFENDANTS
TO RESPOND TO THE SIXTH
AMENDED COMPLAINT

JENNIFER SHAFFER, et al.,

Action Filed: August 30, 2005
Defendants.

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Under Federal Rule of Civil Procedure 6(b)(1)(A) and Local Rules 143 and 144, the parties,

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through their respective counsel of record, agree to a ten-day extension, up to and including

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November 18, 2013, for Defendants to file their response to the sixth amended and supplemental

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complaint, filed on October 8, 2013 (see ECF No. 76). Defendants’ response is currently due on

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November 8, 2013, based on the parties’ stipulation and Court order. (See ECF Nos. 74-75.)

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Good cause exists to grant this extension because defense counsel had and has several
deadlines that will prevent her from completing the response due here. These deadlines include,
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Stipulation and Order for Ten-Day Extension for Defendants to Respond to Sixth Amended Complaint
(2:05-cv-1512-LKK-GGH)

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but are not limited to: motion for summary judgment in Solomon v. Negrete (E.D. Cal. No. 2:10-

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cv-2103 WBS-AC) filed November 6; responsive pleadings in Goodman v. County of San

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Joaquin (E.D. Cal. No. 2:13-cv-0538 MCE-KJN) and Gosselin v. Tilton (E.D. Cal. No. 1:10-cv-

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1974 GSA), filed November 1; and summary judgment in Roberts v. Hernandez (E.D. Cal. No.

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2:11-cv-3308 DAD) due November 14. Defense counsel had/has to meet these deadlines soon

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after completing her last trial that started on October 28 and that resolved shortly thereafter. She

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will therefore not be able to complete Defendants’ response by the current deadline and requires a

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short extension.

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IT IS SO STIPULATED.

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Dated: November 7, 2013

Respectfully submitted,

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KAMALA D. HARRIS
Attorney General of California
CHRISTOPHER J. BECKER
Supervising Deputy Attorney General

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/s/ Diana Esquivel

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DIANA ESQUIVEL
Deputy Attorney General
Attorneys for Defendants

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Dated: November 7, 2013

/s/ Joseph D. Elford
JOSEPH D. ELFORD
Attorneys for Plaintiff

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SA2006300949
31827490.doc

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Stipulation and Order for Ten-Day Extension for Defendants to Respond to Sixth Amended Complaint
(2:05-cv-1512-LKK-GGH)

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ORDER
Based on the parties’ stipulation and good cause appearing, Defendants shall file their
response to the sixth amended complaint on or before November 18, 2013.
IT IS SO ORDERED.

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Dated: November 9, 2013

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/s/ Gregory G. Hollows

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UNITED STATES MAGISTRATE JUDGE
Brod1512.eot.11-13

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Stipulation and Order for Ten-Day Extension for Defendants to Respond to Sixth Amended Complaint
(2:05-cv-1512-LKK-GGH)