California Sportfishing Protection Alliance v. Jensen Precast

Filing 11

STIPULATION and ORDER signed by Judge Frank C. Damrell, Jr. on 9/1/2009 ORDERING 10 that the time within which Defendant must file responsive pleadings to Plaintiff's Complaint is EXTENDED to 10/1/2009. (Reader, L)

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DIANE KINDERMANN HENDERSON (SBN 144426) GLEN C. HANSEN (SBN 166923) KATHERINE J. HART (SBN 191663) Abbott & Kindermann, LLP 2100 21st Street Sacramento, California 95818 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendant JENSEN ENTERPRISES, INC., a Nevada corporation dba in California as JENSEN PRECAST UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA CALIFORNIA SPORTFISHING PROTECTION ALLIANCE, a non-profit corporation, Plaintiff, vs. JENSEN ENTERPRISES, INC., a Nevada corporation, dba in California as JENSEN PRECAST, Defendant. Case No.: 2:09-CV-01517-FCD-EFB SECOND STIPULATION AND ORDER EXTENDING TIME FOR DEFENDANT TO RESPOND TO COMPLAINT Judge: Hon. Frank C. Damrell, Jr. Trial Date: N/A Action Filed: June 2, 2009

This Stipulation And [Proposed] Order Extending Time For Defendant To Respond To Complaint ("Stipulation") is entered into by and between plaintiff California Sportfishing Protection Alliance ("Plaintiff") and defendant Jensen Precast ("Defendant"). The parties to this Stipulation hereby stipulate, by and through their respective counsel, as follows: WHEREAS, Defendant was served with the Complaint and Summons on July 24, 2009, and a responsive pleading is due on August 13, 2009, under the Federal Rules of Civil Procedure; WHEREAS, Defendant requested that the time to file its response to Plaintiff's Complaint be extended to September 1, 2009, and Plaintiff agreed to that request; WHEREAS, the parties continue to diligently pursue settlement, but desire additional time
STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT

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2:09-CV-01517-FCD-EFB

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to negotiate the terms of such proposed settlement, and based on this fact Defendant has requested additional time to file its responsive pleadings; and WHEREAS, Plaintiff has granted Defendant an additional 30 days to file its responsive pleadings if settlement has not been negotiated; NOW THEREFORE, it is hereby stipulated that the time within which Defendant must file responsive pleadings to Plaintiff's Complaint is extended to October 1, 2009. Entry into this Stipulation does not waive Defendant's right to contest this Court's jurisdiction over Defendant or waive any defenses of any kind to Plaintiff's Complaint and/or this action. This Stipulation may be executed by facsimile or electronic signature and in counterparts, all of which, taken together, shall constitute a single stipulation.

Dated: August 31, 2009

ABBOTT & KINDERMANN LLP /s/ Glen C. Hansen (As authorized August 31, 2009) DIANE KINDERMANN HENDERSON GLEN C. HANSEN Attorneys for Defendant Jensen Enterprises, Inc. dba Jensen Precast

Dated: August 31, 2009

LOZEAU DRURY LLP /s/ Douglas Chermak (As authorized August 31, 2009) DOUGLAS CHERMAK Attorneys for Plaintiff California Sportfishing Protection Alliance ORDER

Based upon the foregoing Stipulation and good cause appearing therefore: IT IS SO ORDERED. Dated: September 1, 2009 _______________________________________ FRANK C. DAMRELL, JR. UNITED STATES DISTRICT JUDGE
STIPULATION AND ORDER EXTENDING TIME TO RESPOND TO COMPLAINT

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