Niesen v. Garcia et al

Filing 11

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 4/14/15 ORDERING that if the motion to dismiss is denied, Defendant Bigelow shall respond concurrently with the other Defendants in the same answer within the statutory time period after a denial of the motion. If the motion to dismiss is granted, Defendant Bigelow shall respond to any amended complaint simultaneously with the other Defendants. (Kastilahn, A)

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KEVIN J. DEHOFF, ESQ., SB No. 252106
Email: [e-mail]
AMIE MCTAVISH, ESQ., SB No. 242372
Email: [e-mail]
ANGELO, KILDAY & KILDUFF, LLP
Attorneys at Law
601 University Avenue, Suite 150
Sacramento, CA 95825
Telephone: [phone]

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Telecopier: [phone]

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Attorneys for Defendants COUNTY OF YOLO (also sued erroneously herein as YOLO
COUNTY SHERIFF’S DEPARTMENT and YOLO COUNTY PROBATION DEPARTMENT),
L. GARCIA, J. CEJA, J. LAZARO, M. NEVIS, and V. BIGELOW

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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THERESA MARIE NIESEN,

)
)
Plaintiff,
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vs.
)
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L. GARCIA, YOLO COUNTY SHERIFF’S )
DEPUTY; J. CEJA, YOLO COUNTY
)
SHERIFF’S DEPUTY; J. LAZARO, YOLO )
COUNTY SHERIFF’S DEPUTY; M. NEVIS, )
YOLO COUNTY SHERIFF’S DEPUTY;
)
OFFICER BIGELOW, ANIMAL CONTROL )
OFFICER FOR YOLO COUNTY; YOLO
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COUNTY SHERIFF’S DEPARTMENT;
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YOLO COUNTY PROBATION
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DEPARTMENT, and Does 1 through 50, et al., )
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Defendants.
)
______________________________________ )

Case No.: 2:14-cv-02921-WBS-DAD

STIPULATION EXTENDING TIME FOR
DEFENDANT BIGELOW TO RESPOND
TO PLAINTIFF’S COMPLAINT AND
[PROPOSED] ORDER THEREON

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WHEREAS Defendants COUNTY OF YOLO (also sued erroneously herein as YOLO

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COUNTY SHERIFF’S DEPARTMENT and YOLO COUNTY PROBATION DEPARTMENT),

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L. GARCIA, J. CEJA, J. LAZARO, and M. NEVIS responded to the complaint by filing a

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motion to dismiss, which is set to be heard on April 20, 2015.

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///
-1STIPULATION EXTENDING TIME FOR DEFENDANT BIGELOW TO RESPOND TO PLAINTIFF’S
COMPLAINT AND [PROPOSED] ORDER THEREON

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WHEREAS Defendant V. BIGELOW was served with the complaint after the other
Defendants and thus is not a party to the motion.

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WHEREAS Defendant V. BIGELOW’S response date to the complaint is April 16, 2015.

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WHEREAS Plaintiff’s counsel has agreed to give Defendant BIGELOW a response time

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to the complaint that is contemporaneous with the other Defendants and based upon the Court’s

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ruling on the motion to dismiss.

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WHEREAS this is the parties’ first request for an extension.

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THE PARTIES THEREFORE, BY AND THROUGH THEIR RESPECTIVE

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ATTORNEYS OF RECORD MAKE THE FOLLOWING STIPULATED REQUEST:
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If the motion to dismiss is denied, Defendant BIGELOW will respond

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concurrently with the other Defendants in the same answer within the statutory time period after

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a denial of the motion.

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2.

If the motion to dismiss is granted, Defendant BIGELOW will respond to any

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amended complaint simultaneously with the other Defendants.

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IT IS SO ORDERED.

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Dated: April 14, 2015

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Dated: April 10, 2015

LAW OFFICES OF JULIA M. YOUNG

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/s/ Julia M. Young
[as authorized on 4/10/15]
By:_________________________________
JULIA M. YOUNG
Attorney for Plaintiff THERESA MARIE
NIESEN

-2STIPULATION EXTENDING TIME FOR DEFENDANT BIGELOW TO RESPOND TO PLAINTIFF’S
COMPLAINT AND [PROPOSED] ORDER THEREON

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Dated: April 14, 2015

ANGELO, KILDAY & KILDUFF, LLP
/s/ Kevin J. Dehoff
By:_________________________________
KEVIN J. DEHOFF
AMIE McTAVISH
Attorneys for Defendants COUNTY OF
YOLO, L. GARCIA, J. CEJA, J.
LAZARO, M. NEVIS, and V.
BIGELOW

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-3STIPULATION EXTENDING TIME FOR DEFENDANT BIGELOW TO RESPOND TO PLAINTIFF’S
COMPLAINT AND [PROPOSED] ORDER THEREON