Perez v. Roe et al

Filing 20

STIPULATION and ORDER signed by Judge Morrison C. England, Jr on 12/14/10: The time in which Defendants Roe and Jole may answer, move, or otherwise respond to Plaintiff's First Amended Complaint is extended from December 14, 2010 to January 25, 2010. The time in which the Parties are to submit a joint status report is extended from December 31, 2010 to January 31, 2011. (Kaminski, H)

Perez v. Roe et al

Doc. 20

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RICHARD H. CAULFIELD, SBN 50258 BRIAN C. HAYDON, SBN 154515 ANDREW T. CAULFIELD, SBN 238300 CAULFIELD, DAVIES & DONAHUE, LLP P.O. BOX 277010 Sacramento, CA 95827 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant City of Isleton

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA -o0o-

JUAN MARTINEZ PEREZ, Plaintiff, v. OFFICER W. ROE, in his individual capacity; CHIEF OF POLICE Ronald Jole, in his individual capacity; CITY OF ISLETON, a municipal corporation; and DOES 1 to 50, inclusive,
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Case No. 2:10-CV-01423-MCE-KJN STIPULATION AND ORDER RE ADDITIONAL EXTENSION OF TIME FOR DEFENDANTS JOLE AND ROE TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT AND ADDITIONAL EXTENSION OF JOINT STATUS REPORT SUBMISSION DEADLINE

Defendants.

Plaintiff JUAN MARTINEZ PEREZ ("Plaintiff"), by and through his undersigned counsel, and Defendant CITY OF ISLETON ("City"), by and through its undersigned counsel, and Defendants OFFICER W. ROE ("Roe") and CHIEF OF POLICE Ronald Jole ("Jole") (collectively, the "Parties"), hereby stipulate to the following: 1. WHEREAS, on October 19, 2009 the Parties executed a Stipulation and Order, and

the Court signed the Order (Dkt # 17), which indicated the following: (a) The time in which Defendants Roe and Jole may answer, move, or otherwise respond to Plaintiff's First Amended Complaint was extended from October 15, 2010 to December 14, 2010; (b) The time identified in item number 4 of the Court's Order Requiring Joint Status report in which the Parties are to submit a
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Dockets.Justia.com

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jo int status report that includes the Rule 26(f) discovery plan was extended from within 60 days of service of the complaint on any party, as set forth in the Order, to December 31, 2010; and (c) The case was referred to VDRP. 2. WHEREAS, the Parties subsequently agreed on a neutral for VDRP and scheduled a

VDRP session for December 9, 2010. After the session was confirmed by the neutral, the neutral informed the Parties that due to a calendar conflict she could not participate in a VDRP session on December 9, 2010 as originally indicated. 3. 4. WHEREAS, the Parties have rescheduled the VDRP session for January 11, 2011. WHEREAS, Plaintiff agrees to an additional extension of time for Defendants Roe

and Jole to respond to the First Amended Complaint, making them due on or before 14 days after the Parties complete the VDRP session, or by January 25, 2011. 5. WHEREAS, the Court's Order (Dkt. # 17) requires that the Parties submit a joint

status report that includes the Rule 26(f) discovery plan by December 31, 2010. 6. WHEREAS, the Parties respectfully request that the Court grant an additional

extension of time to submit a joint status report (as required by item number 4 in the Court's Order Requiring Joint Status Report) from December 31, 2010 to January 31, 2011. // // // // // // // // // // // //
2 STIPULATION AND [PROPOSED] ORDER

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED AS FOLLOWS: 1. The time in which Defendants Roe and Jole may answer, move, or otherwise respond

to Plaintiff's First Amended Complaint is extended from December 14, 2010 to January 25, 2010. 2. The time in which the Parties are to submit a joint status report (as required by item

number 4 in the Court's Order Requiring Joint Status Report) is extended from December 31, 2010 to January 31, 2011.

IT IS SO STIPULATED.

Dated: December 14, 2010

CAULFIELD DAVIES & DONAHUE, LLP By:___ ____/s/____________________ Richard H. Caulfield Andrew T. Caulfield Attorneys for Defendant CITY OF ISLETON P.O. Box 277010 Sacramento, CA 95827 [phone]

Dated: December 14, 2010

COLDERBANK LAW By:_______/s/___________________ Tania H. Colderbank Attorney for Plaintiff JUAN MARTINEZ PEREZ 117 J. Street, Suite 300 Sacramento, CA 95814 [phone]

[SIGNATURES CONTINUE ON FOLLOWING PAGE]
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Dated: December 14, 2010 By: _____/s/______ (original signature retained by attorney Andrew T. Caulfield) Defendant OFFICER W. ROE

Dated: December 14, 2010 By: ______/s/_________ (original signature retained by attorney Andrew T. Caulfield) Defendant CHIEF OF POLICE, Ronald Jole

IT IS SO ORDERED. Dated: December 14, 2010 __________________________________ MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE

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