Huggins v. Sierra Joint Community College District et al

Filing 11

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/25/2016 ORDERING Amended Complaint due by 1/29/2016; and that Defendants' time to file a response to the complaint is EXTENDED to 2/12/2016. (Reader, L)

1
2
3
4
5
6
7

ALESA SCHACHTER, ESQ. (SBN 102542)
JASON M. SHERMAN, ESQ. (SBN 245190)
JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation
California Plaza
2180 Harvard Street, Suite 560
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail] / [e-mail]
Attorneys for DEFENDANTS:
SIERRA JOINT COMMUNITY COLLEGE DISTRICT; SIERRA COLLEGE; BEN NOONAN;
LUCAS MOOSMAN; and ROZ GOLDENBERG

8
UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

9

11
12
13
14
15
16
17
18
19

NEBRASKA HUGGINS,

)
)
)
)
Plaintiff,
)
)
)
v.
)
SIERRA JOINT COMMUNITY COLLEGE )
)
DISTRICT; SIERRA COLLEGE; BEN
)
NOONAN; LUCAS MOOSMAN, ROZ
GOLDENBERG, and DOES 1-10, inclusive, )
)
)
)
Defendants.
)

CASE NO. 2:15-cv-02098-WBS-CKD
STIPULATION AND ORDER FOR
EXTENSION TO DEFENDANTS TO FILE
RESPONSIVE PLEADING UNTIL
PLAINTIFF FILES AN AMENDED
COMPLAINT

Complaint Filed:

October 7, 2015

Trial Date:

None Set

20
21
22
23
24
25
26
27
28
1
STIPULATION AND ORDER FOR EXTENSION TO DEFENDANTS TO FILE RESPONSIVE
PLEADING UNTIL PLAINTIFF FILES AN AMENDED COMPLAINT

1
2
3

Pursuant to Local Rule 144(a), the parties agree and stipulate that Defendants should be
granted additional time to file a responsive pleading for the following reasons:
-

4
5

Following a meet and confer process between counsel, Plaintiff has agreed to file an
amended complaint to address various issues raised by defense counsel;

-

6

Defendants’ responsive pleading is due on January 29, 2016 if a further extension is
not granted by the Court;

7

-

Plaintiff intends to file the amended complaint by Friday, January 29, 2016;

8

-

As this is the last day for Defendants to respond to the Complaint, Defendants would
not have sufficient time to prepare a responsive pleading should, for whatever reason,

10
11
TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

9

Plaintiff be unable to file the amended complaint by January 29, 2016;
-

12

In order to avoid any possible waivers or negative consequences, Defendants should
be granted an extension while Plaintiff prepares and files the amended complaint.

13

The parties therefore agree and stipulate that Defendants should be granted an additional

14

extension to file a response to Plaintiff’s Complaint, and further agree that Defendants’ rights to

15

raise any objections and motions under Rule 12 as to the First Amended Complaint are

16

preserved.

17
18
19

The parties request an order from the Court that Defendants’ time to file a response to
Plaintiff’s Complaint be extended for two additional weeks, to Friday, February 12, 2016.
Dated: January 22, 2016
JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation

20
21
/s/ Alesa Schachter_________________________
ALESA SCHACHTER

22
23
24

Dated: January 22, 2016

Attorneys for DEFENDANTS
LAW OFFICE OF STEWART KATZ

25
26
27
28

/s/ Stewart Katz (as authorized on 1/22/16)___
STEWART KATZ
Attorneys for PLAINTIFF

2
STIPULATION AND ORDER FOR EXTENSION TO DEFENDANTS TO FILE RESPONSIVE
PLEADING UNTIL PLAINTIFF FILES AN AMENDED COMPLAINT

1
2
3

PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: January 25, 2016

4
5
6
7
8

10
11
TELEPHONE: [phone] / FACSIMILE: [phone]

TELEPHONE: [phone] / FACSIMILE: [phone]

A PROFESSIONAL LAW CORPORATION

2180 HARVARD STREET, SUITE 560
SACRAMENTO, CA 95815

JOHNSON SCHACHTER & LEWIS

9

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

3
STIPULATION AND ORDER FOR EXTENSION TO DEFENDANTS TO FILE RESPONSIVE
PLEADING UNTIL PLAINTIFF FILES AN AMENDED COMPLAINT