Foothill Church, et al. v. Rouillard
Filing
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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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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
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Casey Mattox (Virginia Bar No. 47148)*
ALLIANCE DEFENDING FREEDOM
440 First Street, NW, Suite 600
Washington, DC 20001
(202) 393-8690
cmattox@ADFlegal.org
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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
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*Admitted pro hac vice
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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FOOTHILL CHURCH, CALVARY CHAPEL
OF CHINO HILLS, and SHEPHERD OF THE
HILLS CHURCH,
Plaintiffs, STIPULATION AND ORDER TO EXTEND
TIME TO FILE AMENDED COMPLAINT
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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.
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Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB)
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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.
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Respectfully submitted,
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Dated: September 5, 2017
ALLIANCE DEFENDING FREEDOM
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/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
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Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB)
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Dated: September 5, 2017
XAVIER BECERRA
Attorney General of California
SUSAN M. CARSON
Supervising Deputy Attorney General
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/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
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Stipulation and Order to Extend Time to File Amended Complaint (CV-02165-KJM-EFB)
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ORDER
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Upon stipulation of the parties, and good cause appearing, the Court hereby grants Plaintiffs
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an additional 30 days to file any amended complaint, extending the time to file to October 23,
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2017.
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IT IS SO ORDERED
DATED: September 11, 2017.
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UNITED STATES DISTRICT JUDGE
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[Proposed] Order Extending Time to File Amended Complaint (CV-02165-KJM-EFB)
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