Mecklenberg v. Georgetown Divide Public Utility District

Filing 6

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 5/14/2014 re: 5 Stipulation and Proposed Order; ORDERING defendant's time to respond to Plaintiff's Complaint is EXTENDED to 6/6/2014. (Waggoner, D)

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Barbara A. Brenner - SB# 142222
Ian J. Barlow – SB# 262213
CHURCHWELL WHITE LLP
1201 K Street, Suite 710
Sacramento, CA 95814
[phone] Phone
[phone] Fax

fees exempt pursuant to
Government Code §6103

Attorneys for Defendant
GEORGETOWN DIVIDE PUBLIC UTILITY DISTRICT

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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STACY MECKLENBERG,
Plaintiff,

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vs.

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GEORGETOWN DIVIDE PUBLIC UTILITY
DISTRICT AND DOES 1 THROUGH 10,

Case No.: 2:14-cv-00750-TLN-DAD
STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO COMPLAINT
[E.D. Cal. Local R. 144(a)]
Action Filed: March 24, 2014

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Defendants.
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Churchwell
White LLP

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Stipulation and Order to Extend Time to Respond to Complaint

Plaintiff STACY MECKLENBERG (“Plaintiff”) and defendant GEORGETOWN

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DIVIDE PUBLIC UTILITY DISTRICT (“Defendant”), hereafter collectively referred to as the

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“Parties”, by and through their respective counsel of record, hereby stipulate and agree that:

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WHEREAS, Plaintiff filed the above-entitled action on March 24, 2014;

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WHEREAS, Plaintiff granted Defendant a twenty-eight day extension of time to respond

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to Plaintiff’s Complaint and the Parties filed their Stipulation for Extension of Time to Respond to

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Complaint for Damages and Injunctive Relief on April 14, 2014;
WHEREAS, Defendant’s response to Plaintiff’s Complaint is currently due on May 16,

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2014;
WHEREAS, Defendant’s counsel requested, and Plaintiff’s counsel recently provided,

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examples of Plaintiff’s billing statements with enlarged text and Plaintiff’s counsel has agreed

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that these examples may be shared and discussed with Defendant at an upcoming board meeting

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in an effort to resolve this litigation;

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WHEREAS, the Parties do not wish to incur further fees in preparing or opposing

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responsive motions or pleadings at this time and do not wish to cause the Court to use its time in

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considering responses to the Complaint if such efforts may be obviated;
WHEREAS, Plaintiff and Defendant are therefore in agreement that Defendant’s

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deadline to answer or otherwise respond to the Complaint may be extended by three weeks to

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June 6, 2014;

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WHEREAS, an extension of time will not alter the date(s) of any event or deadline that
has been set by the Court; and

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WHEREAS, good cause exists for this extension to facilitate potential resolution of this

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Churchwell
White LLP

matter and conserve the resources of the Parties, counsel and the Court.

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Stipulation and Order to Extend Time to Respond to Complaint

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STIPULATION
THEREFORE, the Parties to this action, by and through their respective attorneys,
stipulate:
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Defendant’s time to respond to Plaintiff’s Complaint is extended to June 6, 2014.

Respectfully submitted,

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DATED: _May 14, 2014

CHURCHWELL WHITE LLP

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By_________________________________
BARBARA A. BRENNER
Attorneys for Defendant
Georgetown Divide Public Utility District

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DATED: _May 14, 2014

CENTER FOR DISABILITY ACCESS

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By_________________________________
PHYL GRACE
Attorneys for Plaintiff
Stacy Mecklenberg

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IT IS SO ORDERED.

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Dated: May 14, 2014

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Troy L. Nunley
United States District Judge

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White LLP

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Stipulation and Order to Extend Time to Respond to Complaint