Fonseca v. Kaiser Permanente Medical Center Roseville, et al.

Filing 66

STIPULATION AND ORDER signed by District Judge Kimberly J. Mueller on 7/19/2016 ORDERING Defendant Karen Smith to respond to the #64 Second Amended Complaint by 8/31/2016. (Michel, G.)

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KAMALA D. HARRIS
Attorney General of California
ISMAEL A. CASTRO
Supervising Deputy Attorney General
ASHANTE L. NORTON
Deputy Attorney General
State Bar No. 203836
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendant Karen Smith, M.D., in
her official capacity as Director of the California
Department of Public Health

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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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JONEE FONSECA, AN INDIVIDUAL
PARENT AND GUARDIAN OF ISRAEL
STINSON, A MINOR, PLAINTIFF,

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v.

Case No. 2:16-cv-00889-KJM-EFB

STIPULATION EXTENDING TIME TO
RESPOND TO THE SECOND
Plaintiff, AMENDED COMPLAINT FOR
DECLARATORY RELIEF AND ORDER
THEREON

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[L.R. 144(a)]
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KAISER PERMANENTE MEDICAL
CENTER ROSEVILLE; DR. MICHAEL
MYETTE M.D.; KAREN SMITH, M.D. IN
HER OFFICIAL CAPACITY AS
DIRECTOR OF THE CALIFORNIA
DEPARTMENT OF PUBLIC HEALTH;
AND DOES 2 THROUGH 10, INCLUSIVE,
Defendants. Judge:

The Honorable Kimberly J.
Mueller

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Action Filed: May 9, 2016
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Pursuant to Local Rule 144(a), Plaintiff Jonee Fonseca and Defendant Karen Smith, M.D.,

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in her official capacity as Director of the California Department of Public Health, by and through

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their respective counsel, hereby stipulate to grant Defendant Karen Smith, M.D. in her official
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Stipulation Extending Time to Respond to the Second Amended Complaint for Declaratory Relief and Order
Thereon (2:16-cv-00889-KJM-EFB)

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capacity as Director of the California Department of Public Health additional time to respond to

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Plaintiff’s Second Amended Complaint for Declaratory Relief, served on July 1, 2016, as follows:

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WHEREAS, the Second Amended Complaint states claims and issues not raised in the prior

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complaints;
WHEREAS, Defendant Smith desires additional time to prepare and file her responsive
pleadings to this action;
WHEREAS, Plaintiff is willing to provide additional time for Defendant Smith to prepare
and file her responsive pleadings;
WHEREAS, the parties have not previously extended the time to respond to the Second
Amended Complaint;
NOW, THEREFORE, BASED ON THE FOREGOING FACTS, THE PARTIES HEREBY

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STIPULATE THAT Defendant Smith’s last day to file her response to the Second Amended

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Complaint for Declaratory Relief on file in this matter is extended from the original due date of

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July 22, 2016, up to and including August 31, 2016.

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IT IS SO STIPULATED AND AGREED.
Dated: July 14, 2016

Respectfully Submitted,

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KAMALA D. HARRIS
Attorney General of California
ISMAEL A. CASTRO
Supervising Deputy Attorney General

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/s/ Ashante L. Norton

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ASHANTE L. NORTON
Deputy Attorney General
Attorneys for Defendant
Karen Smith, M.D.
Respectfully Submitted,

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Dated: July 14, 2016

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Pacific Justice Institute

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/s/ Kevin T. Snider

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KEVIN T. SNIDER
Chief Counsel
Attorneys for Plaintiff
Jonee Fonseca

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2

Stipulation Extending Time to Respond to the Second Amended Complaint for Declaratory Relief and Order
Thereon (2:16-cv-00889-KJM-EFB)

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ORDER THEREON
Based on the Parties’ above Joint Stipulation, IT IS HEREBY SO ORDERED THAT

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Defendant Smith’s time to serve and file a response to Plaintiff’s Second Amended Complaint for

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Declaratory Relief in the above entitled action be extended from July 22, 2016 to August 31,

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2016 pursuant to Local Rule 144(a).

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DATE: July 19, 2016

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UNITED STATES DISTRICT JUDGE

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Stipulation Extending Time to Respond to the Second Amended Complaint for Declaratory Relief and Order
Thereon (2:16-cv-00889-KJM-EFB)