Hartnett v. Placer County Superior Court, et al

Filing 45

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 1/16/15 re 43 EXTENDING time to respond to the operative complaint to 4/30/15. (Meuleman, A)

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PLACER COUNTY COUNSEL’S OFFICE
Crystal M. Center (SBN 287845)
175 Fulweiler Avenue
Auburn, California 95603
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants COUNTY OF PLACER, PLACER COUNTY
DEPARTMENT OF HEALTH AND HUMAN SERVICES, RICHARD J.
BURTON, KEVIN HENDERSON, DIANA RYAN, H. PAUL SANDERS,
APRIL CAREW, KATHY TANNER, KAREN SCHLANGER, TOM LIND,
CANDYCE SKINNER, and ROMNEY LYNN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Stacey Victoria Hartnett,

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Plaintiff,
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vs.
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COUNTY OF PLACER, a public entity;
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PLACER COUNTY DEPARTMENT OF
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HEALTH AND HUMAN SERVICES (CSOC), )
a public entity, PLACER COUNTY COURT
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APPOINTED SPECIAL ADVOCATES
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(CASA), a public entity, RICHARD J.
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BURTON, M.D., M.P.H., DIRECTOR, as an
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individual and in official capacity; KEVIN
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HENDERSON, as an individual and in official )
capacity; DIANA RYAN, Program Supervisor, )
as an individual and in official capacity; H.
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PAUL SANDERS, as an individual and in
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official capacity; April Carew, as an individual )
and in official capacity; KATHY TANNER, as )
an individual and in official capacity; KAREN )
SCHLANGER, as an individual and in official )
capacity; TOM LIND, as an individual and in
)
official capacity; CANDACE SKINNER, as an )
individual and in official capacity; ROMNEY
)
LYNN, as an individual and in official capacity; )
DON KLEINDER, CASA DIRECTOR, as an
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Case No. 2:13-cv-1636-GEB-KJN
STIPULATION AND [PROPOSED]
ORDER RE EXTENSION OF TIME TO
FILE RESPONSE TO COMPLAINT

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Stipulation and Proposed Order re Extension of Time to File Answer to Complaint

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individual and in official capacity; TAMARA
LARSON, CASA worker as an individual and
in official capacity; and Does 1 through 25,
inclusive,
Defendants.

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IT IS HEREBY STIPULATED between Plaintiff Stacey Victoria Hartnett and Defendants

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Placer County, Placer County Health and Human Services (CSOC), Richard J. Burton, Kevin

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Henderson, Diana Ryan, H. Paul Sanders, April Carew, Kathy Tanner, Karen Schlanger, Candace

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Skinner, Tom Lind, Romney Lynn, Don Kleinder and Tamara Larson that the time for these

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Defendants to respond to the operative complaint shall be extended to April 30, 2015. The time to

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respond is being requested to allow Crystal M. Center, counsel for Placer County defendants, who

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will be on maternity leave beginning on or before February 4, 2015 until on or about April 8, 2015,

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adequate time to respond to Plaintiff’s complaint following the decision rendered by the court on

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Defendants’ Motions to Dismiss currently set for hearing on January 20, 2015.

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Pursuant to Local Rule 144(a), stipulations in excess of 28 days to answer or otherwise
respond to a complaint must be approved by the Court.
IT IS SO STIPULATED.
PLACER COUNTY COUNSEL’S OFFICE

Dated: January 10, 2015
By:

/s/ Crystal M. Center
CRYSTAL CENTER
Attorneys for Defendants COUNTY OF
PLACER, PLACER COUNTY DEPARTMENT
OF HEALTH AND HUMAN SERVICES,
RICHARD J. BURTON, KEVIN
HENDERSON, DIANA RYAN, H. PAUL
SANDERS, APRIL CAREW, KATHY
TANNER, KAREN SCHLANGER, TOM
LIND, CANDYCE SKINNER, and ROMNEY
LYNN

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Stipulation and Proposed Order re Extension of Time to File Answer to Complaint

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Dated:

By:

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STROWBRIDGE BLASDEL RICHARDSON
Attorney for Stacey Hartnett

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Dated:

By:

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Ron Enabnit
Attorney for DON KLEINDER, CASA and
TAMARA LARSON, CASA

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ORDER

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Pursuant to the parties’ stipulation, the time to respond to the operative complaint is hereby

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extended to April 30, 2015.

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IT IS SO ORDERED.

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Dated: January 16, 2015

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Stipulation and Proposed Order re Extension of Time to File Answer to Complaint