J.M. et al v. Pleasant Ridge Union School District et al

Filing 18

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 10/7/2016 ORDERING that Defendant Alliance Redwoods Conference Grounds' time to respond to the Complaint is EXTENDED to 11/1/2016. (Zignago, K.)

LEWIS BRISBOIS BISGAARD & SMITH LLP
1 JOSEPH R. LORDAN, SB# 265610
Email: [e-mail]
2 CHINA WESTFALL, SB# 300982
Email: [e-mail]
3 333 Bush Street, Suite 1100
San Francisco, California 94104-2872
4 Telephone: [phone]
Facsimile: 415.434.0882
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Attorneys for ALLIANCE REDWOODS
6 CONFERENCE GROUNDS (sued as Alliance
Redwoods Outdoor Recreation)
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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J.M., a minor, by and through her Guardian ad
11 litem, NANCY MORIN-TEAL and NANCY
MORIN-TEAL, an individual,
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Plaintiff,
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vs.
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PLEASANT RIDGE UNION SCHOOL
15 DISTRICT, MAGNOLIA INTERMEDIATE
SCHOOL, ALLIANCE REDWOODS
16 OUTDOOR RECREATION, COUNTY OF
NEVADA and DOES 1 to 50,
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Defendants.
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CASE NO. 2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING
ORDER TO EXTEND TIME TO
ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO
LOCAL RULE 144(a)

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Plaintiffs J.M., a minor, by and through her Guardian ad Litem Nancy Morin-Teal, and

21 Nancy Morin-Teal (“Plaintiffs”), and Defendant Alliance Redwoods Conference Grounds (sued as
22 Alliance Redwoods Outdoor Recreation (“Defendant”), by and through their respective attorneys
23 of record, stipulate as follows:
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1. On April 29, 2016, Plaintiffs filed a Complaint against Defendants Alliance Redwoods

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Conference Grounds, Pleasant Ridge Union School District, Magnolia Intermediate

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School, the County of Nevada, and Does 1 to 50.

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2. Plaintiffs served the Complaint on Defendant Alliance Redwoods Conference Grounds on
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2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)

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August 30, 2016.
3. On September 23, 2016, Plaintiffs and Defendant Alliance Redwoods Conference Grounds

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stipulated that Defendant’s deadline to answer or otherwise respond to Plaintiffs’

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Complaint would be October 14, 2016.

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4. On October 3, 2016, the Court heard oral arguments on Defendant Pleasant Ridge Union
School District’s motion to dismiss. The Court took the motion under submission.

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5. On October 4, 2016, counsel for Defendant Alliance Redwoods Conference Grounds met

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and conferred with Plaintiffs’ counsel regarding Defendant’s intent to file a motion to

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dismiss. Plaintiffs’ counsel stated he is amenable to amending the Complaint to address

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the deficiencies noted by defense counsel for Alliance Redwoods Conference Grounds.

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6. In the interest of efficiency, Plaintiffs’ Counsel and counsel for Alliance Redwoods

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Conference Grounds seek an order extending Defendant’s time to respond to the

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Complaint to November 1, 2016.

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7. This extension will allow Plaintiffs’ counsel to file a single amended Complaint which

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addresses the deficiencies raised by counsel for Alliance Redwoods Conference Grounds

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as well as any deficiencies found by the Court in its forthcoming Order on Pleasant Ridge

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Union School District’s motion to dismiss.

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8. This change will not alter the date of any deadlines already fixed by Court order.

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9. This change will not affect the other parties who have appeared in this action.

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2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)

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DATED: October 6, 2016

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By:

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/s/ China Westfall
Joseph R. Lordan
China M. Westfall
Attorneys for Defendant Alliance Redwoods
Conference Grounds (sued as Alliance Redwoods
Outdoor Recreation)

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DATED: October 6, 2016

AMERIO LAW FIRM., P.C.

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By:

/s/ Jeffrey Fletterick
Jeffrey Fletterick
Attorneys for Plaintiffs
J.M., a minor, by and through her Guardian and
Litem Nancy Morin-Teal, and Nancy Morin-Teal

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2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)

SIGNATURE ATTESTATION

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I hereby attest that all signatories listed above, on whose behalf this Stipulation is

3 submitted, concur in the filing’s content and have authorized this filing.
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6 DATED: October 6, 2016

LEWIS BRISBOIS BISGAARD & SMITH

LLP

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By:
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/s/ China Westfall
Joseph R. Lordan
China Westfall
Attorneys for Defendant Alliance Redwoods
Conference Grounds (sued as Alliance Redwoods
Outdoor Recreation)

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2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)

[PROPOSED] ORDER

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The Parties having so stipulated and good cause appearing,

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IT IS HEREBY ORDERED that Defendant Alliance Redwoods Conference Grounds’

4 time to respond to the Complaint is extended to November 1, 2016.
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Dated: October 7, 2016

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2:2016-cv-00897-WBS-CKD
JOINT STIPULATION REQUESTING ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND
TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)

CERTIFICATE OF SERVICE
J.M. v. Pleasant Ridge Union School District, et al.
USDC– Eastern, Sac Div, Case No.: 2:2016-cv-00897-WBS-CKD

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STATE OF CALIFORNIA, COUNTY OF SAN FRANCISCO

At the time of service, I was over 18 years of age and not a party to the action. My
5 business address is 333 Bush Street, Suite 1100, San Francisco, CA 94104-2872. I am employed
in the office of a member of the bar of this Court at whose direction the service was made.
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On October 6, 2016, I served the following document(s):
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JOINT STIPULATION FOR EXTENTION OF TIME TIME TO ANSWER OR
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OTHERWISE RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 144(a)
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I served the documents on the following persons at the following addresses (including fax
numbers and e-mail addresses, if applicable):
SEE ATTACHED SERVICE LIST

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The documents were served by the following means:

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(BY E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
documents to be sent to the persons at the e-mail addresses listed above. I did not receive,
within a reasonable time after the transmission, any electronic message or other indication
that the transmission was unsuccessful.

I declare under penalty of perjury under the laws of the United States of America and the
16 State of California that the foregoing is true and correct.
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Executed on October 6, 2016, at San Francisco, California.

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/s/ Sharice Valenzuela
SHARICE VALENZUELA

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CERTIFICATE OF SERVICE

2:2016-cv-00897-WBS-CKD

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SERVICE LIST
J.M. v. Pleasant Ridge Union School District, et al.
USDC– Eastern, Sac Div, Case No.: 2:2016-cv-00897-WBS-CKD

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Ashley R. Amerio, Esq.
4 Jeffrey Fletterick, Esq.
AMERIO LAW FIRM, P.C.
5 1651 Response Road, Suite 111
Sacramento, CA 95815
6 Tel: [phone]
Fax: [phone]
7 Email: [e-mail]
[e-mail]
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Attorneys for Plaintiff
9 J.M. and her Guardian ad Litem, NANCY
MORIN
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Kristin Alisan Blocher
11 LAW OFFICES OF KRISTIN A.
BLOCHER
12 P.O. Box 491
Sacramento, CA 95812
13 Tel:
916.945.2720
Fax: [phone]
14 Email: [e-mail]
15 Attorney for Defendant
PLEASANT RIDGE UNION SCHOOL
16 DISTRICT

Cori Rae Sarno, Esq.
Kristin Alisan Blocher, Esq.
ANGELO, KILDAY & KILDUFF, LLP
601 University Avenue, Suite 150
Sacramento, CA 95825
Tel:
916.564.6100 x229
Fax: [phone]
Email: [e-mail]
Attorney for Defendant
PLEASANT RIDGE UNION SCHOOL
DISTRICT
Amanda Uhrhammer
County Of Nevada
950 Maidu Avenue
Nevada City, CA 95959
Tel: [phone]
Email: [e-mail]
Attorney for Defendant
COUNTY OF NEVADA

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CERTIFICATE OF SERVICE

2:2016-cv-00897-WBS-CKD