Steffen v. Union Pacific Railroad Company et al

Filing 27

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/8/17 ORDERING that Defendant TIM PAXIN's PACIFIC EXCAVATION, INC. erroneously sued as PACIFIC EXCAVATION, INC.'s deadline to respond to Plaintiff's First Amended Complaint is 2/27/2017. (Mena-Sanchez, L)

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1 2 3 4 5 6 7 Jennifer K. Stinnett, Esq. (SBN 228209) Marysia S. Okreglak, Esq. (SBN 1991348) CHRISTENSEN EHRET LLP 2485 Natomas Park Drive, Suite 315 Sacramento, CA 95833 Tel.: (916) 443-6909 / Fax: (916) 313-0645 jstinnett@christensenlaw.com mokreglak@christensenlaw.com Attorneys for Defendant TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 CHRISTENSEN EHRET LLP 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KATIE M. STEFFEN, ) ) Plaintiff, ) ) vs. ) ) UNION PACFIC RAILROAD COMPANY, a ) Delaware Corporation, BRIAN L. KLINE, and ) DOES 1 through 10, inclusive, ) ) Defendants. ) ) ) ) Case No.: 2:15-CV-01025-TLN-KJN STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. TO RESPOND TO FIRST AMENDED COMPLAINT First Amended Complaint Filed: January 6, 2017 Pursuant to Local Rule 144 of the United States District Court, Eastern District, all parties hereby stipulate and request that the Court enter an order extending Defendant TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneously sued as PACIFIC EXCAVACTION, INC. (“Defendant”) to file an answer or other responsive pleading by approximately twenty (20) days. 1. On or about January 6, 2017, Plaintiff KATIE M. STEFFEN (“Plaintiff”) filed a First Amended Complaint, adding two Doe defendants, including Defendant. 2. An executed Summons indicates this Defendant was served on January 17, 2017. 3. Counsel for Defendant was retained only days before a responsive pleading was due and has not the opportunity to review the file and prepare a responsive pleading. -1STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. TO RESPOND TO FIRST AMENDED COMPLAINT 1 4. In order to allow Defendant sufficient time to prepare a responsive pleading, 2 counsel for Defendant and the parties hereby agree to extend the time for Defendant to file an 3 answer or other responsive pleading to February 27, 2017. 4 5. 5 This Stipulation can be executed in counterparts and copies of signatures will be treated as Therefore, the parties respectfully request that the Court so order. 6 originals. 7 IT IS SO STIPULATED: 8 9 DATED: February 7, 2017 DREYER BABICH BUCCOLAR WOOD, et al. 10 CHRISTENSEN EHRET LLP 11 By: 12 /s/ HANK G. GREENBLATT, Esq. Attorneys for Plaintiff KATIE M. STEFFEN 13 14 DATED: February 7, 2017 CHRISTENSEN EHRET LLP 15 16 By: 17 18 /s/ JENNIFER K. STINNETT, Esq. MARYSIA S. OKREGLAK, Esq. Attorneys for Defendant TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. 19 20 DATED: February 7, 2017 UNION PACIFIC RAILROAD LAW DEPT. 21 22 23 24 By: /s/ JOHN DANIEL FEENEY, Esq. Attorneys for Defendant UNION PACIFIC RAILROAD COMPANY 25 26 27 28 -2STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. TO RESPOND TO FIRST AMENDED COMPLAINT 1 ORDER 2 Pursuant to the Stipulation of all parties and good cause shown, Defendant TIM PAXIN’S 3 PACIFIC EXCAVATION, INC. erroneously sued as PACIFIC EXCAVATION, INC.’S deadline 4 to respond to Plaintiff’s First Amended Complaint is February 27, 2017. 5 IT IS SO ORDERED. 6 7 DATED: February 8, 2017 8 9 Troy L. Nunley United States District Judge 10 CHRISTENSEN EHRET LLP 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TIM PAXIN’S PACIFIC EXCAVATION, INC. erroneous sued as PACIFIC EXCAVATION, INC. TO RESPOND TO FIRST AMENDED COMPLAINT

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