Foothill Church, et al. v. Rouillard

Filing 71

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 9/11/17. The Court hereby GRATS Plaintiffs an additional 30 days to file any amended complaint, EXTENDING the time to file to 10/23/17. (Mena-Sanchez, L)

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1 2 3 4 5 Erik Stanley (Arizona Bar No. 030961)* Kevin Theriot (Arizona Bar No. 030446)* Jeremiah Galus (Arizona Bar No. 030469)* Alliance Defending Freedom 15100 N. 90th Street Scottsdale, AZ 85260 (480) 444-0020 estanley@ADFlegal.org ktheriot@ADFlegal.org jgalus@ADFlegal.org 6 7 8 9 10 Casey Mattox (Virginia Bar No. 47148)* ALLIANCE DEFENDING FREEDOM 440 First Street, NW, Suite 600 Washington, DC 20001 (202) 393-8690 cmattox@ADFlegal.org 13 Alexander M. Medina (California Bar No. 222015) MEDINA McKELVEY LLP 983 Reserve Drive Roseville, CA 95678 (916) 960-2211 alex@medinamckelvey.com Attorneys for Plaintiffs 14 *Admitted pro hac vice 11 12 15 IN THE UNITED STATES DISTRICT COURT 16 FOR THE EASTERN DISTRICT OF CALIFORNIA 17 SACRAMENTO DIVISION 18 19 20 21 FOOTHILL CHURCH, CALVARY CHAPEL OF CHINO HILLS, and SHEPHERD OF THE HILLS CHURCH, Plaintiffs, STIPULATION AND ORDER TO EXTEND TIME TO FILE AMENDED COMPLAINT 22 23 24 25 26 2:15-CV-02165-KJM-EFB v. MICHELLE ROUILLARD, in her official capacity as Director of the California Department of Managed Health Care, Dept: Judge: Courtroom 3, 15th Fl. Hon. Kimberly J. Mueller Defendant. 27 28 Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Plaintiffs Foothill Church, Calvary Chapel Chino Hills, and Shepherd of the Hills Church, and Defendant Michelle Rouillard, in her official capacity as Director of the California Department of Managed Health Care, by and through their attorneys of record, submit this stipulated request to extend the time for Plaintiffs to file an amended complaint. Counsel for the parties have conferred on this matter and, in support of this joint request, hereby STIPULATE and AGREE as follows: 1. On September 1, 2017, the Court granted Defendant’s motion to dismiss Plaintiffs’ first amended complaint for failure to state a claim. The Court granted Plaintiffs leave to amend and ordered that Plaintiffs file an amended complaint, if any, within 21 days (ECF No. 68); 2. Plaintiffs’ counsel has advised counsel for Defendant that they have competing litigation demands in other cases over the next several weeks and that Plaintiffs have thus determined that it is necessary to request an extension of time to file any second amended complaint in this case; and 3. Defendant’s counsel has agreed to Plaintiffs’ request for an additional 30 days to file any second amended complaint, thereby extending the time to file a second amended complaint to October 23, 2017. 17 18 Respectfully submitted, 19 Dated: September 5, 2017 ALLIANCE DEFENDING FREEDOM 20 21 22 23 24 25 26 /s/ Jeremiah Galus JEREMIAH GALUS (admitted pro hac vice) ALLIANCE DEFENDING FREEDOM 15100 N. 90th Street Scottsdale, AZ 85260 (480) 444-0020 jgalus@ADFlegal.org Attorneys for Plaintiffs Foothill Church, Calvary Chapel Chino Hills, and Shepherd of the Hills Church 27 28 1 Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB) 1 2 Dated: September 5, 2017 XAVIER BECERRA Attorney General of California SUSAN M. CARSON Supervising Deputy Attorney General 3 4 5 6 7 8 /s/ Joshua Sondheimer (as authorized on 9/5/17) JOSHUA N. SONDHEIMER Deputy Attorney General Attorneys for Defendant Michelle Rouillard, in her official capacity as Director of the California Department of Managed Health Care 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB) 1 ORDER 2 Upon stipulation of the parties, and good cause appearing, the Court hereby grants Plaintiffs 3 4 an additional 30 days to file any amended complaint, extending the time to file to October 23, 5 2017. 6 7 IT IS SO ORDERED DATED: September 11, 2017. 8 9 UNITED STATES DISTRICT JUDGE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 [Proposed] Order Extending Time to File Amended Complaint (CV-02165-KJM-EFB)

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