B.O.L.T. et al v. City of Rancho Cordova et al

Filing 30

STIPULATION and ORDER signed by Judge Garland E. Burrell, Jr on 2/2/15 ORDERING that the time for Defendants to respod to the operative Complaint in this Action is EXTENDED to 2/23/2015. IT IS FURTHER ORDERED, that Plaintiffs' referenced Second Amended Complaint shall be filed no later than 2/10/15. (Mena-Sanchez, L)

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A PROFESSIONAL CORPORATION
Terence J. Cassidy, SBN 99180
Kristina M. Hall, SBN 196794
350 University Avenue, Suite 200
Sacramento, California 95825
[phone] (telephone)
[phone] (facsimile)

Attorneys for Defendants

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Gary W. Gorski (SBN 166526)
LAW OFFICES OF GARY W. GORSKI
1207 Front Street, Suite 15
Sacramento, CA 95814
[phone]
Daniel M. Karalash (SBN 176422)
Strategic Law Command
1207 Front Street, Suite 15
Sacramento, CA 95814

Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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B.O.L.T. an unincorporated association of
motorcycle riders and enthusiasts; MARK
TEMPLE; JOHN DALKE; LAWRENCE
“WOLF” HAVEN; NOREEN McNULTY;
WARREN PEARL; LYLE
DUVAUCHELLE; JEFFREY RABE;
DAVID ZALITSKIY; WILLIAM
LANGHORNE; THOMAS BELL; ROBERT
BALTHORPE II;

Case No. 2:14-cv-01588-GEB-DAD
STIPULATION AND [PROPOSED] TO
EXTEND TIME FOR DEFENDANTS TO
FILE A RESPONSIVE PLEADING, FOR
PLAINTIFFS TO FILE A SECOND
AMENDED COMPLAINT, AND FOR
SERVICE OF SAME

Plaintiffs,

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vs.
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CITY OF RANCHO CORDOVA, a political
subdivision of the State of California;
COUNTY OF SACRAMENTO; a political
subdivision of the State of California;
RANCHO CORDOVA POLICE
DEPARTMENT, an independent legal agency
of the COUNTY OF SACRAMENTO and the

Complaint filed July 4, 2014

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STIPULATION AND [PROPOSED] TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSIVE PLEADING, FOR
PLAINTIFFS TO FILE A SECOND AMENDED COMPLAINT, AND FOR SERVICE OF SAME

{01359442.DOC}

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CITY OF RANCHO CORDOVA;
SACRAMENTO COUNTY SHERIFF’S
DEPARTMENT; MICHAEL GOOLD, in his
official capacity as the Chief of Police of the
CITY OF RANCHO CORDOVA; RANCHO
CORDOVA POLICE TRAFFIC SERGEANT
G. LANE, in his individual and official
capacity as Supervisor of the Traffic Division;
SCOTT R. JONES, in his official capacity as
the SHERIFF of the COUNTY OF
SACRAMENTO; RANCHO CORDOVA
POLICE OFFICER S. CARROZZO (badge
number 480); RANCHO CORDOVA
POLICE OFFICER M. JAMES (badge
number 507; RANCHO CORDOVA POLICE
OFFICER S. PADGETT (badge number
1174),
Defendants.
____________________________________/

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and Defendants,

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by and through their undersigned Counsel, pursuant to Eastern District Local Rule 143 and 144 as

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follows:

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1)

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The parties have met and conferred regarding deficiencies and ambiguities in the
First Amended Complaint filed.

2)

In the interest of expediting this matter, the parties agree that a Second Amended

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Complaint would expedite the law and motion process, and resolve any technical

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deficiencies.

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3)

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is currently due Monday, February 2, 2015.
4)

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Defendants’ responsive pleading and/or motion as to the First Amended Complaint

The parties respectfully request that the Court extend the time for Defendants to file
a responsive pleading and/or motion up to and including February 23, 2015.

5)

The parties stipulate and further respectfully request that the Court grant Plaintiffs

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leave to file a Second Amended Complaint by February 10, 2015, with a draft

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emailed to Defendants on February 3, 2015, for the purposes of further meet and

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confer.

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STIPULATION AND [PROPOSED] TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSIVE PLEADING, FOR
PLAINTIFFS TO FILE A SECOND AMENDED COMPLAINT, AND FOR SERVICE OF SAME

{01359442.DOC}

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6)

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This Stipulation may be signed in counterparts and any facsimile or electronic
signature shall be as valid as an original signature.

IT IS SO STIPULATED.

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Dated: February 2, 2015

Respectfully submitted,
LAW OFFICES OF GARY W. GORSKI

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By __/s/Gary W. Gorski_______
Gary W. Gorski

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STRATEGIC LAW COMMAND
/c/Daniel M. Karalash
Daniel M. Karalash

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Attorneys for Plaintiffs

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Dated: February 2, 2015

PORTER SCOTT
A PROFESSIONAL CORPORATION

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By /s/ Kristina M. Hall
Terence J. Cassidy
Kristina M. Hall
Attorneys for Defendants
CITY OF RANCHO CORDOVA, COUNTY
OF SACRAMENTO, RANCHO CORDOVA
POLICE DEPARTMENT, SACRAMENTO
COUNTY SHERIFF’S DEPARTMENT,
MICHAEL GOOLD, G. LANE, SCOTT R.
JONES, S. CARROZZO, M. JAMES, and S.
PADGETT

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ORDER
Having reviewed the above stipulation, IT IS HEREBY ORDERED that the time for

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Defendants to respond to the operative Complaint in this action be, and hereby is, extended to
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February 23, 2015;
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IT IS FURTHER ORDERED, that Plaintiffs referenced Second Amended Complaint shall
be filed no later than February 10, 2015.
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STIPULATION AND [PROPOSED] TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSIVE PLEADING, FOR
PLAINTIFFS TO FILE A SECOND AMENDED COMPLAINT, AND FOR SERVICE OF SAME

{01359442.DOC}

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IT IS SO ORDERED.
Dated: February 2, 2015

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STIPULATION AND [PROPOSED] TO EXTEND TIME FOR DEFENDANTS TO FILE A RESPONSIVE PLEADING, FOR
PLAINTIFFS TO FILE A SECOND AMENDED COMPLAINT, AND FOR SERVICE OF SAME

{01359442.DOC}