Hunt v. County of El Dorado et al

Filing 50

STIPULATION and ORDER signed by Judge Frank C. Damrell, Jr on 4/14/11 ORDERING that Plaintiff TANYA HUNT shall file and serve her Third Amended Complaint in this matter within seven (7) days of the date this Stipulation is signed by counsel for Defen dant COUNTY OF EL DORADO. It is further stipulated to by and between counsel for all parties that Defendants shall have the option of filing a notification with the Court that their Answer to the Second Amended Complaint (filed January 27, 2011) shall be deemed to be their answer to this Third Amended Complaint, or filing a separate answer to the Third Amended Complaint. (Becknal, R)

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Douglas E. Watts, SBN 182274
WATTS LAW OFFICES
1745 Creekside Dr.
Folsom, CA 95630
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
David M. Poore, SBN 192541
BROWN / POORE LLP
2200 Powell Street, Suite 745
Emeryville, California 94608
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Plaintiff
TANYA HUNT

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A PROFESSIONAL CORPORATION
Nancy J. Sheehan, SBN 109419
Beatriz Berumen, SBN 271249
350 University Avenue, Suite 200
Sacramento, California 95825
[phone]
[phone] (facsimile)
[e-mail]
[e-mail]
Attorneys for Defendants: COUNTY OF EL DORADO and FRED KOLLAR
BARKETT & GUMPERT
Franklin G. Gumpert, SBN 66051
P.O. Box 661448
Sacramento, CA 95866
Telephone: [phone]
Attorney for Defendants: PHIL CHOVANEC, DARIN LEWIS, BOB ASHWORTH and JACKIE NOREN
JACKSON LEWIS LLP
C. Christine Maloney, SBN 226575
199 Fremont Street, 10th Floor
San Francisco, CA 94105
Telephone: [phone]
Attorney for Defendant: KEVIN HOUSE

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STIPULATION REGARDING PLAINTIFF’S FILING OF THIRD AMENDED COMPLAINT; ORDER
HUNT v. COUNTY OF EL DORADO, ET AL., CASE NO. 2:10-cv-01367-FCD-KJM

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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TANYA HUNT,

CASE NO. 2:10-CV-01367-FCD-KJM

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Plaintiffs,

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STIPULATION REGARDING PLAINTIFF’S
FILING OF THIRD AMENDED COMPLAINT;
ORDER

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vs.

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COUNTY OF EL DORADO; PHIL
CHOVANEC; DARIN LEWIS; KEVIN
HOUSE; BOB ASHWORTH; JACKIE
NOREN, and Does 1 through 50, inclusive

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Defendants.

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WHEREAS the operative pleading in this matter is Plaintiff’s Second Amended Complaint,
filed on January 27, 2011; and

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WHEREAS Plaintiff filed new charges of discrimination and retaliation with the California
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Department of Fair Employment and Housing (“DFEH”) and the federal Equal Employment

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Opportunity Commission (“EEOC”) arising out of her termination from employment with Defendant

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COUNTY OF EL DORADO on December 22, 2010; and

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WHEREAS Plaintiff has obtained a Right-To-Sue letter from both the DFEH and the EEOC

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relative to these new charges; and
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WHEREAS the parties wish to avoid the expense, delay, and consumption of this Court’s time
with a noticed motion for leave of court to file Plaintiff’s Third Amended Complaint;
The parties to this case do hereby stipulate and agree that Plaintiff TANYA HUNT shall file and

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serve her Third Amended Complaint in this matter within seven (7) days of the date this Stipulation is
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signed by counsel for Defendant COUNTY OF EL DORADO. It is further stipulated to by and
between counsel for all parties that Defendants shall have the option of filing a notification with the

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STIPULATION REGARDING PLAINTIFF’S FILING OF THIRD AMENDED COMPLAINT; ORDER
HUNT v. COUNTY OF EL DORADO, ET AL., CASE NO. 2:10-cv-01367-FCD-KJM

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Court that their Answer to the Second Amended Complaint (filed January 27, 2011) shall be deemed to
be their answer to this Third Amended Complaint, or filing a separate answer to the Third Amended

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Complaint.
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IT IS SO STIPULATED.

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Dated: April 14, 2011

WATTS LAW OFFICES

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By/Douglas E. Watts/ (as authorized on 04/14/11 )
Douglas E. Watts
Attorney for Plaintiff
TANYA HUNT

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Dated: April 14, 2011

BROWN / POORE LLP

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By/David M. Poore/ (as authorized on 04/14/11 )
David M. Poore
Co-Attorney for Plaintiff
TANYA HUNT

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Dated: April 14, 2011

BARKETT & GUMPERT

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By/Franklin G. Gumpert/ (as authorized on 04/14/11)
Franklin G. Gumpert
Attorney for Defendants
PHIL CHOVANEC, DARIN LEWIS, BOB
ASHWORTH and JACKIE NOREN

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Dated: April 14, 2011

JACKSON LEWIS LLP

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By/C. Chistine Maloney/ (as authorized on 04/14/11 )
C. Christine Maloney
Attorney for Defendant
KEVIN HOUSE

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STIPULATION REGARDING PLAINTIFF’S FILING OF THIRD AMENDED COMPLAINT; ORDER
HUNT v. COUNTY OF EL DORADO, ET AL., CASE NO. 2:10-cv-01367-FCD-KJM

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Dated: April 14, 2011

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By/Nancy J. Sheehan/ (as authorized on 04/14/11 )
Nancy J. Sheehan
Beatriz Berumen
Attorneys for Defendants
COUNTY OF EL DORADO and
FRED KOLLAR

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ORDER

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Having reviewed the above Stipulation, and good cause appearing.

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IT IS SO ORDERED.

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Dated: April 14, 2011

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

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STIPULATION REGARDING PLAINTIFF’S FILING OF THIRD AMENDED COMPLAINT; ORDER
HUNT v. COUNTY OF EL DORADO, ET AL., CASE NO. 2:10-cv-01367-FCD-KJM