Ludavico v. Sacramento County et al

Filing 71

STIPULATION and ORDER 70 signed by Judge Frank C. Damrell, Jr on 8/19/2011 GRANTING Defendants until August 29, 2011 to file a responsive pleading to Plaintiffs' Second Corrected Amended Complaint. (Krueger, M)

William E. Bonham, SB# 55478
Attorney at Law
916 Second Street, 2nd Floor, Ste. A
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Plaintiffs: Thomas LUDAVICO, Sr., Thomas LUDAVICO, Jr., Ashley LUDAVICO
A PROFESSIONAL CORPORATION

Michael W. Pott, SBN 186156
Derek J. Haynes, SBN 264621
350 University Ave., Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]
[e-mail]

[e-mail]
Attorneys for Defendants SACRAMENTO COUNTY, SACRAMENTO COUNTY SHERIFF’S
DEPARTMENT, JOHN MCGINNESS, DANIEL ZUNIGA, ADRIAN ZUNIGA, DEPUTY
POWE, DEPUTY HELLER (erroneously sued as “MUELLER”) and DEPUTY SCHANNEP
(erroneously sued as “SCHANAP”)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
THOMAS LUDAVICO, Sr., THOMAS CASE NO. 2:08-CV-01473-FCD-JFM
LUDAVICO, Jr.; ASHLEY LUDAVICO,
Plaintiffs,

STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANTS TO
vs.
FILE A RESPONSE TO PLAINTIFFS’
SECOND CORRECTED SECOND
SACRAMENTO COUNTY, a Government AMENDED COMPLAINT
Entity; SACRAMENTO COUNTY SHERIFF’S
DEPARTMENT, a Public Entity; JOHN
MCGINNESS, an individual; ELK GROVE Complaint Filed: 06/24/2008
UNIFIED SCHOOL DISTRICT, a Public Entity; 2nd Corrected 2nd Amended Complaint
DANIEL ZUNIGA, an individual; ADRIAN Filed: 08/05/2011
ZUNIGA, an individual; JIM ROSE, an
individual; DEPUTY POWE, an individual;
DEPUTY MUELLER, an individual; DEPUTY
SCHANAP, an individual; and DOES 1 to 50,
inclusive,
Defendants.
_______________________________________/

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSE TO
PLAINTIFFS’ SECOND CORRECTED SECOND AMENDED COMPLAINT

Pursuant to Local Rule 144(a), it is hereby stipulated and agreed by and between Plaintiffs
THOMAS LUDAVICO, SR., THOMAS LUDAVICO, JR., AND ASHLEY LUDAVICO and
Defendants

SACRAMENTO

COUNTY,

SACRAMENTO

COUNTY

SHERIFF’S

DEPARTMENT, JOHN MCGINNESS, DANIEL ZUNIGA, ADRIAN ZUNIGA, DEXTER
POWE, MICHAEL HELLER, BRETT SCHANNEP, GREG HANKS, CHRIS MORA, JOHN
SYDOW, and CHRIS WEIGHTMAN, by and through their respective undersigned counsel, that
Defendants may have until August 29, 2011 to respond to Plaintiffs’ Second Corrected Second
Amended Complaint [Docket No. 68].
The extension will allow the parties to focus their time and resources on the upcoming
Voluntary Dispute Resolution Session scheduled for August 24, 2011. If that session does not
result in a settlement, Defendants will move forward with filing their response to Plaintiffs’
Second Corrected Second Amended Complaint. Defendants obtained one prior extension of time
to respond to Plaintiffs’ First Amended Complaint, but have not received an extension with
respect to the Second Corrected Second Amended Complaint.
IT IS SO STIPULATED

Dated: August 19, 2011

PORTER SCOTT
A PROFESSIONAL CORPORATION
By /s/ Michael W. Pott
Michael W. Pott
Derek J. Haynes
Attorneys for Defendants

Dated: August 18, 2011
By: /s/ William E. Bonham (authorized 08/18/11)
William E. Bonham
Attorney for Plaintiffs

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSE TO
PLAINTIFFS’ SECOND CORRECTED SECOND AMENDED COMPLAINT

ORDER
This Court, having considered the parties stipulation, orders that Defendants
SACRAMENTO COUNTY, SACRAMENTO COUNTY SHERIFF’S DEPARTMENT, JOHN
MCGINNESS, DANIEL ZUNIGA, ADRIAN ZUNIGA, DEXTER POWE, MICHAEL HELLER,
BRETT SCHANNEP, GREG HANKS, CHRIS MORA, JOHN SYDOW, and CHRIS
WEIGHTMAN may have until August 29, 2011 to file a responsive pleading to Plaintiffs’ Second
Corrected Second Amended Complaint.
IT IS SO ORDERED.

Dated: August 19, 2011

_______________________________________
FRANK C. DAMRELL, JR.
UNITED STATES DISTRICT JUDGE

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSE TO
PLAINTIFFS’ SECOND CORRECTED SECOND AMENDED COMPLAINT