Mammen et al v. County of Sacramento et al

Filing 48

STIPULATION and ORDER 47 setting deadline and extending time signed by Judge John A. Mendez on 6/17/2014. Plaintiff's Third Amended Complaint shall be filed on or before 6/30/2014 and submission of Joint Case Management Statement shall be postponed until 30 days after Court rules on Motion directed at Third Amended Complaint, or if no Motion is filed, 30 days after State Defendants file an Answer to Third Amended Complaint. (Marciel, M)

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Jay T. Jambeck SBN #226018
Mandy G. Leigh SBN # 225748
LEIGH LAW GROUP
870 Market Street, Suite 1157
San Francisco, CA 94102
Telephone: [phone]
Facsimile:
415-795-3733
Email: [e-mail]
Attorneys for Plaintiffs
A.P. (a minor); Robin Mammen
and Larry Mammen individually
and as Guardian Ad Litem

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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A.P. (a minor); ROBIN MAMMEN and
LARRY MAMMEN individually and as
Guardian Ad Litem for A.P.,

2:13-cv-01588 JAM-AC

Plaintiffs, JOINT STIPULATION SETTING TIME
FOR FILING OF PLAINTIFFS’ THIRD
v.
AMENDED COMPLAINT AND
EXTENDING TIME FOR JOINT CASE
COMMUNITY CARE LICENSING,
MANAGEMENT CONFERENCE
MICHELLE WONG; CHILDREN’S LAW STATEMENT
CENTER; COUNTY OF SACRAMENTO,
STEPHANIE LYNCH, LUIS VILLA;
Judge:
John A. Mendez
MICHELLE CALLEJAS, DEBRA
Trial Date:
None Set
WILLIAMS, CRAIG LARKIN, RENAE
Complaint Filed: August 1, 2013
RODOCKER
Defendants.

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JOINT STIPULATION SETTING TIME FOR THE FILING OF PLAINTIFFS’ THIRD
AMENDED COMPLAINT AND EXTENDING TIME FOR CASE MANAGEMENT
CONFERENCE

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Pursuant to Local Rule 144(a), Plaintiffs Robin Mammen, et. al., Defendants Community
Care Licensing and Michelle Wong in her official capacity (collectively “State Defendants”), and
County of Sacramento, Stephanie Lynch, Michelle Callejas, Debra Williams, Renae Rodocker,
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Joint Stipulation Setting Deadline and Extending Time for Joint Case Management Conference Statement
(2:13-cv-01588 JAM-AC)

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Luis Villa and Craig Larkin (collectively “County Defendants”) by and through their respective

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counsel, hereby stipulate to a date for the filing of Plaintiffs’ Third Amended Complaint and to

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postpone the submission of their Joint Case Management Conference Statement as set forth

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below:

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WHEREAS, on June 9, 2014 the Court granted the Motion to Dismiss the Second Amended

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Complaint of Defendants Community Care Licensing and Michelle Wong in her official capacity

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(collectively “State Defendants”) with leave to amend certain portions of the complaint;

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WHEREAS, no specific date was set forth in the Court’s order for the filing of Plaintiffs’
Third Amended Complaint;
WHEREAS, the parties have agreed to a deadline of 21 days from the issuance of the
Court’s June 9, 2014 Order for Plaintiffs to file their Third Amended Complaint;
WHEREAS, this extension is sought so that the parties may enhance efficiency and meet

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and confer as to the submission of the Joint Case Management Conference Statement pending the

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resolution of motions directed at the Third Amended Complaint or the filing of an Answer;

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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 parties agree to postpone the submission of the Joint Case Management

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Statement until thirty (30) days after any motion directed at the Third Amended Complaint is

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ruled upon, or if no motion is filed, within thirty (30) days of the filing of an Answer by the State

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Defendants;

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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

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Plaintiff’s Third Amended Complaint shall be filed on or before June 30, 2014 and that

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submission of the Joint Case Management Statement shall be postponed until thirty (30) days

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after the Court rules on a motion directed at the Third Amended Complaint, or if no motion is

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filed, thirty (30) days after the State Defendants file an Answer to the Third Amended Complaint.

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Joint Stipulation Setting Deadline and Extending Time for Joint Case Management Conference Statement
(2:13-cv-01588 JAM-AC)

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Respectfully submitted,

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LEIGH LAW GROUP
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Dated: June 13, 2014

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/s/ Jay T. Jambeck
__________________
JAY T. JAMBECK
Leigh Law Group
Attorneys for Plaintiffs Robin Mammen, et. al.

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Dated:

June 13, 2014

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

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/s/ Renu R. George_____________________
RENU R. GEORGE
Deputy Attorney General
Attorneys for Defendants Community Care
Licensing, Michelle Wong, in her official
capacity

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LONGYEAR, O’DAY & LAVRA, LLP
Dated:

June 13, 2014

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/s/ Amanda L. McDermott__________________
AMANDA L. MCDERMOTT
Attorneys for County Defendants

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IT IS SO ORDRED

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Dated: 6/17/2014
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/s/ John A. Mendez_______________________
Hon. John A. Mendez
UNITED STATES DISTRICT COURT JUDGE

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Joint Stipulation Setting Deadline and Extending Time for Joint Case Management Conference Statement
(2:13-cv-01588 JAM-AC)