Fitzgerald v. County of El Dorado et al

Filing 15

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 2/1/13. The amended complaint is due on or before 1/29/13. (Manzer, C)

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JILL P. TELFER, ( State Bar No. 145450)
LAW OFFICES OF JILL P. TELFER
A Professional Corporation
331 J Street, Suite 200
Sacramento, California 95814
Telephone: [phone]
Facsimile:
[phone]
[e-mail]

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Attorneys for Plaintiff
RICHARD FITZGERALD

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UNITED STATES DISTRICT COURT FOR THE
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EASTERN DISTRICT OF CALIFORNIA
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RICHARD FITZGERALD,
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Plaintiffs,
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vs.
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EL DORADO COUNTY; SHERIFF JOHN
D’AGOSTINI, UNDERSHERIFF RICH
WILLIAMS and DOES 1 through 20,
inclusive,
Defendants.

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CASE NO.: 2:12-cv-02932-MCE-KJN
STIPULATION TO FILE FIRST
AMENDED COMPLAINT AND MOTION
FOR LEAVE TO AMEND THE
COMPLAINT ON OR BEFORE
JANUARY 29, 2013

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Richard Fitzgerald, the plaintiff in this action, and El Dorado County; Sheriff John
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D’Agostini and Undersheriff Rich Williams, the defendants, stipulate and consent, in writing, within
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the meaning of Rule 15(a) of the Federal Rules of Civil Procedure, that Plaintiff may file a First
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Amended Complaint. The Proposed First Amended complaint is to be filed with the Motion for
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Leave to Amend on or before January 29, 2013. This agreement is based on the parties’ meet and
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confer efforts to resolve perceived pleading deficiencies.
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Stipulation Filing Amended Complaint and Leave to Amend

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DATE: January 22, 2013

LAW OFFICES OF JILL P. TELFER
A Professional Corporation

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/s/ Jill P. Telfer
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JILL P. TELFER
Attorney for Plaintiff
RICHARD FITZGERALD

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DATE: January 22, 2013

PORTER, SCOTT
A Professional Corporation

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/s/ Nancy J. Sheehan
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NANCY J. SHEEHAN
KRISTINA M. HALL
Attorney for Defendant
SHERIFF JOHN D’AGOSTINI and
UNDERSHERIFF RICH WILLIAMS

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DATE: January 22, 2013

FOSTER EMPLOYMENT LAW
A Professional Corporation

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/s/ Christine Maloney
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CHRISTINE MALONEY
Attorney for Defendant
EL DORADO COUNTY

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IT IS SO ORDERED.
Dated: February 1, 2013

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__________________________________________
MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT JUDGE

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Stipulation Filing Amended Complaint and Leave to Amend

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