Arnold v. County of Sacramento et al

Filing 13

REQUEST to continue Scheduling Conference and related dates by 45 days by Connie Arnold. (Attachments: # 1 Proposed Order) (Lim, Mary) Modified on 9/24/2012 (Kaminski, H)

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1 2 3 4 5 6 7 8 JEFF A. HARRISON (SBN 151227) MARY J. LIM (SBN 272170) METZ & HARRISON, LLP 139 Richmond Street El Segundo, CA 90245 Tel: (310) 414-9400 Fax: (310) 414-9200 JHarrison@metzharrison.com MLim@metzharrison.com Attorneys for Plaintiff, CONNIE ARNOLD 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 CONNIE ARNOLD 13 Plaintiff, 14 15 16 17 18 19 20 vs. COUNTY OF SACRAMENTO; SACRAMENTO PUBLIC LIBRARY AUTHORITY; SUNRISE RECREATION & PARK DISTRICT; and DOES 1 through 50, inclusive, Defendants. 21 22 23 24 ) Case No.: 12-CV-01998-LKK-EFB ) Civil Rights ) ) REQUEST TO CONTINUE ) SCHEDULING CONFERENCE AND ) RELATED DATES BY 45 DAYS ) ) Current Dates ) Last Day for Meeting ) of Counsel: 10/01/2012 ) Status Reports Due: 10/09/2012 ) Scheduling Conference: 10/22/2012 ) ) Requested Dates ) Last Day for Meeting ) of Counsel: 11/15/2012 ) Status Reports Due: 11/23/2012 ) Scheduling Conference: 12/06/2012 ) 25 TO ALL PARTIES, THEIR ATTORNEYS OF RECORD, AND THE UNITED 26 STATES DISTRICT COURT: 27 Plaintiff CONNIE ARNOLD (“Plaintiff”), by and through her respective 28 ________________________________________________________________________________________________ REQUEST TO CONTINUE SCHEDULING CONFERENCE AND RELATED DATES BY 45 DAYS Case No. 12-CV-01998-LKK-EFB 1 1 counsel, hereby requests that the Court continue the date for the scheduling 2 conference and related dates. Good cause exists for continuing these dates. 3 1. On July 31, 2012, Plaintiff filed a Complaint in this action. 4 2. The Court promptly issued an Order setting a pretrial scheduling 5 conference for October 22, 2012, which requires the Parties to conduct their Fed. R. 6 Civ. P. 26(f) meeting of counsel by October 1, 2012 and file their status reports by 7 October 9, 2012. 8 3. On August 27, 2012, based on newly obtained information, Plaintiff 9 filed a First Amended Complaint to add a necessary party to the action before any of 10 the Defendants had filed a response. 11 12 13 4. To date, only Defendant SUNRISE RECREATION & PARK DISTRICT has filed a responsive pleading. 5. Counsel for Defendants SACRAMENTO PUBLIC LIBRARY 14 AUTHORITY and COUNTY OF SACRAMENTO is unknown to Plaintiff at this 15 time as Defendants are not required to file a responsive pleading until October 4, 16 2012 and October 5, 2012, respectively. 17 6. In order to give the Parties adequate time to conduct a meeting of 18 counsel and to prepare meaningful status reports, Plaintiff requests that the Court 19 continue the scheduling conference by forty-five (45) days. 20 21 7. Prior to the filing of this request, Plaintiff contacted the Court and confirmed that Plaintiff may make this request. 22 23 Dated: September 21, 2012 METZ & HARRISON, LLP 24 25 26 27 By: JEFF A. HARRISON MARY J. LIM Attorneys for Plaintiff, CONNIE ARNOLD 28 ________________________________________________________________________________________________ REQUEST TO CONTINUE SCHEDULING CONFERENCE AND RELATED DATES BY 45 DAYS Case No. 12-CV-01998-LKK-EFB 2

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