Jewett v. California Forensic Medical Group et al

Filing 61

ORDER signed by District Judge Morrison C. England, Jr. on 5/16/2016 ORDERING that the deadline to file plaintiff's Fifth Amended Complaint is EXTENDED to 5/30/2016. (Reader, L)

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KEKER & VAN NEST LLP
STEVEN P. RAGLAND - # 221076
[e-mail]
AJAY S. KRISHNAN - # 222476
[e-mail]
TAYLOR GOOCH - # 294282
[e-mail]
633 Battery Street
San Francisco, CA 94111-1809
Telephone:
415 391 5400
Facsimile:
415 397 7188
ATABEK & ASSOCIATES
Jon A. Atabek, Esq. - # 269497
57 Bianco
Irvine, CA 92618
Telephone:
213 394 5943
Facsimile:
213 402 3413

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DISABILITY RIGHTS LEGAL CENTER
Anna Rivera - # 239601
[e-mail]
Kara Janssen - # 274762
256 S. Occidental Blvd., Suite B
Los Angeles, CA 90057
Telephone:
213 736 1031
Facsimile:
213 736 1428

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LAW OFFICES OF JEROME M. VARANINI
JEROME MARTIN VARANINI - # 58531
[e-mail]
641 Fulton Avenue, Suite 200
Sacramento, CA 95825
Telephone:
916 993 4868
Facsimile:
916 993 6750
Attorneys for Defendants CALIFORNIA
FORENSIC MEDICAL GROUP, INC., DR.,
JEREMY AUSTIN, MARY BARNES, AND
JAMES ROEMMICH
BRICKWOOD LAW OFFICE
GARY CHARLES BRICKWOOD - # 94892
[e-mail]
1135 Pine Street, Suite 210
Redding, CA 96001
Telephone:
530 245 1877
Facsimile:
530 245 1879

Attorneys for Plaintiffs EVERETT JEWETT

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Attorney for Defendant SHASTA COUNTY
SHERIFF'S DEPARTMENT

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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EVERETT JEWETT,

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Plaintiffs,
v.
SHASTA COUNTY SHERIFF’S
DEPARTMENT, A PUBLIC ENTITY; Dr.
JEREMY AUSTIN, an individual; MARY
BARNS, an individual; JAMES
ROEMECH, an individual; Tom Bosenko,
as Sheriff of the Shasta County, and
SHASTA COUNTY, a public entity; and
CALIFORNIA FORENSIC MEDICAL
GROUP, INC. a private entity,
Defendants.

Case No. 2:13-cv-0882 MCE AC (PC)
STIPULATION AND ORDER RE
MOTION FOR AN EXTENSION TO FILE
PLAINTIFF’S FIFTH AMENDED
COMPLAINT
Date Filed: May 16, 2013
Trial Date:

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The parties, through their attorneys of record, stipulate and jointly request that the Court

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extend the deadline to either file, or seek leave to file, Plaintiff’s Amended Complaint. The

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parties have stipulated to a 14-day extension.

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1.

The parties have previously filed, and been granted, three requests for an extension

of the discovery cut-off date and dispositive motion deadline. The parties’ prior requests for an
extension of the discovery cut-off were granted on March 4, 2015, August 28, 2015, and March
16, 2016.
2.

This is the parties’ first request for an extension of Plaintiff’s deadline to file, or

seek leave to file, Plaintiff’s Amended Complaint. Plaintiff transmitted a copy of the Amended
Complaint to Defendants on Tuesday, May 10, 2016. The Defendants requested additional time
to review the Amended Complaint so that they may consider whether to stipulate to the Amended
Complaint’s filing. The Plaintiff believes this request to be reasonable as a stipulation would
avoid additional motion practice.
3.

The parties hereby stipulate and jointly request that the Court extend the due date

for Plaintiff to file, or seek leave to file, its amended complaint by 14-days.

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Dated: May 13, 2016

KEKER & VAN NEST LLP

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By:

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Attorneys for Plaintiffs
EVERETT JEWETT
LAW OFFICES OF JEROME M.
VARANINI

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/s/ Steven P. Ragland
STEVEN P. RAGLAND
AJAY S. KRISHNAN
TAYLOR GOOCH

Dated: May 13, 2016

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By:

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Attorneys for Defendants
CALIFORNIA FORENSIC MEDICAL
GROUP, INC., DR., JEREMY AUSTIN,
MARY BARNES, AND JAMES
ROEMMICH

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1059959.01

/s/ Jerone Varanini
JEROME MARTIN VARANINI

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Dated: May 13, 2016

BRICKWOOD LAW OFFICE

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By:

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/s/Gary Charles Brickwood
GARY CHARLES BRICKWOOD
Attorneys for Defendant SHASTA
COUNTY SHERIFF'S DEPARTMENT

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I hereby attest that I have on file all holographic signatures corresponding to any
signatures indicated by a conformed signature (/S/) within this e-filed document.

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ORDER RE MOTION FOR AN EXTENSION TO FILE PLAINTIFF’S FIFTH
AMENDED COMPLAINT
On May 13, 2016, the parties, through their attorneys of record, filed a Stipulation and
Joint Motion for an Extension to File Plaintiff’s Fifth Amended Complaint. Good cause
appearing, the motion is granted.
Accordingly, IT IS HEREBY ORDERED, that the deadline of May 16, 2016 to file, or
seek leave to file, Plaintiff’s Amended Complaint is extended to May 30, 2016.
IT IS SO ORDERED.
Dated: May 16, 2016

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1059959.01