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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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.: [phone] / Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
TIM PAXIN’S PACIFIC EXCAVATION, INC.
erroneous sued as PACIFIC EXCAVATION, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CHRISTENSEN EHRET LLP

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KATIE M. STEFFEN,

)
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Plaintiff,
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vs.
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UNION PACFIC RAILROAD COMPANY, a )
Delaware Corporation, BRIAN L. KLINE, and )
DOES 1 through 10, inclusive,
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Defendants.
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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.
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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

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4.

In order to allow Defendant sufficient time to prepare a responsive pleading,

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counsel for Defendant and the parties hereby agree to extend the time for Defendant to file an

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answer or other responsive pleading to February 27, 2017.

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5.

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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.

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originals.

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IT IS SO STIPULATED:

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DATED: February 7, 2017 DREYER BABICH BUCCOLAR WOOD, et al.

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CHRISTENSEN EHRET LLP

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By:

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/s/
HANK G. GREENBLATT, Esq.
Attorneys for Plaintiff
KATIE M. STEFFEN

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DATED: February 7, 2017 CHRISTENSEN EHRET LLP

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By:

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/s/
JENNIFER K. STINNETT, Esq.
MARYSIA S. OKREGLAK, Esq.
Attorneys for Defendant
TIM PAXIN’S PACIFIC EXCAVATION, INC.
erroneous sued as PACIFIC EXCAVATION, INC.

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DATED: February 7, 2017 UNION PACIFIC RAILROAD LAW DEPT.

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By:

/s/
JOHN DANIEL FEENEY, Esq.
Attorneys for Defendant
UNION PACIFIC RAILROAD COMPANY

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-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

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ORDER

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Pursuant to the Stipulation of all parties and good cause shown, Defendant TIM PAXIN’S

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PACIFIC EXCAVATION, INC. erroneously sued as PACIFIC EXCAVATION, INC.’S deadline

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to respond to Plaintiff’s First Amended Complaint is February 27, 2017.

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IT IS SO ORDERED.

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DATED: February 8, 2017

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Troy L. Nunley
United States District Judge

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CHRISTENSEN EHRET LLP

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-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