Mammen et al v. County of Sacramento et al

Filing 26

STIPULATION and ORDER signed by Judge John A. Mendez on 12/11/13: Defendants' time to serve and file a response to Plaintiffs' First Amended Complaint shall be extended from December 21, 2013 to January 9, 2014. (Kaminski, H)

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KAMALA D. HARRIS, State Bar No. 146672
Attorney General of California
ISMAEL A. CASTRO, State Bar No. 85452
Supervising Deputy Attorney General
RENU R. GEORGE, State Bar No. 262310
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants Community Care
Licensing, Michelle Wong, Leon “Geoff” Wells in
their official capacity

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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ROBIN MAMMEN, LARRY MAMMEN
Individually and as Guardian Ad Litem for
A.P.,

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v.

2:13-cv-01588 JAM-AC

JOINT STIPULATION EXTENDING
TIME FOR STATE DEFENDANTS TO
Plaintiffs, RESPOND TO FIRST AMENDED
COMPLAINT AND ORDER THEREON
[Local Rule 144(a)]

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COUNTY OF SACRAMENTO,
DEPARTMENT OF HEALTH AND
HUMAN SERVICES; ANNE EDWARDS;
MICHELLE CALLEJAS; LUIS VILLA;
STEPHANIE LYNCH; DEBBIE
WILLIAMS; CRAIG LARKEN; RENAE
RODOCKER; MIRI MEE; JACK
DANIEL; JEANINE LOPEZ; REY
CARBONI; COMMUNITY CARE
LICENSING; MICHELLE WONG;
GEOFF WELLS; BRENDA CHANEY;
CHILDREN'S LAW CENTER; DANA
PETERS; AND DOES 1-100, INCLUSIVE

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Defendants.

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Judge:
John A. Mendez
Trial Date:
None Set
Complaint Filed: August 1, 2013

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Joint Stipulation Extending Time for State Defendants to Answer Complaint and [Proposed] Order thereon [Local
Rule 144(a) (2:13-cv-01588 JAM-AC)

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JOINT STIPULATION EXTENDING TIME FOR STATE DEFENDANTS TO
RESPOND TO FIRST AMENDED COMPLAINT

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Pursuant to Local Rule 144(a), Plaintiffs Robin Mammen, et. al., and Defendants

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Community Care Licensing, Michelle Wong, and Leon “Geoff” Wells in their official capacity

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(collectively “State Defendants”), by and through their respective counsel, hereby stipulate to

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grant State Defendants additional time to respond to Plaintiffs’ First Amended Complaint as set

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forth below:

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WHEREAS, Plaintiffs filed a Complaint on August 1, 2013 and a First Amended
Complaint on November 18, 2013 naming Community Care Licensing, Michelle Wong, and Leon
“Geoff” Wells as Defendants in this action;
WHEREAS, on November 21, 2013, Plaintiffs served Defendant Community Care
Licensing with the Summons and First Amended Complaint;

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WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a)(1)(A)(i), Defendant

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Community Care Licensing’s response to Plaintiffs’ First Amended Complaint is due December

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12, 2013;

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WHEREAS, State Defendants require additional time in which to respond to Plaintiffs’
First Amended Complaint;

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WHEREAS, this extension is sought so that State Defendants may enhance efficiency and

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respond to Plaintiffs’ First Amended Complaint on behalf of Community Care Licensing as well

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as the remaining State Defendants not yet served;

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WHEREAS, in the interest of justice and in an effort to enhance judicial efficiency and

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preserve resources, the Plaintiffs agree to grant State Defendants additional time in which to

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respond to the Complaint;

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WHEREAS, the extension sought will not alter the date of any event or deadline already
fixed by Court Order.
NOW THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE that the time

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in which State Defendants shall respond to the Complaint in this action shall be continued until

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January 9, 2014.
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Joint Stipulation Extending Time for State Defendants to Answer Complaint and [Proposed] Order thereon [Local
Rule 144(a) (2:13-cv-01588 JAM-AC)

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Respectfully submitted,

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KAMALA D. HARRIS
Attorney General of California
ISMAEL A. CASTRO
Supervising Deputy Attorney General

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Dated: December 6, 2013

/s/ Renu R. George_____________________
RENU R. GEORGE
Deputy Attorney General
Attorneys for Defendants Community Care
Licensing, Michelle Wong, Leon “Geoff” Wells,
in their official capacity

Dated:

/s/ Dennise Henderson__________________
DENNISE SUZANNE HENDERSON
Law Office of Dennise Henderson
Attorneys for Plaintiffs Robin Mammen, et. al.

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December 6, 2013

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ORDER THEREON
Based on the Parties’ above Joint Stipulation, IT IS HEREBY SO ORDERED THAT the

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Defendants’ time to serve and file a response to Plaintiffs’ First Amended Complaint in the above

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entitled action be extended from December 21, 2013 to January 9, 2014 pursuant to Local Rule

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144(a).

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DATE: 12/11/2013

/s/ John A. Mendez________________________
JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

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Joint Stipulation Extending Time for State Defendants to Answer Complaint and [Proposed] Order thereon [Local
Rule 144(a) (2:13-cv-01588 JAM-AC)