A.T. v. Dry Creek Joint Elementary School District et al

Filing 68

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 7/6/2017 ORDERING Plaintiff will have 40 days from 6/20/2017 to file first Amended Complaint. Plaintiff's FAC shall therefore be filed no later than 7/31/2017. ORDERING De fendant Wendy DeVore will be permitted to forego responding to Plaintiff's original Complaint and instead will respond to Plaintiff's First Amended Complaint. ORDERING that the parties will have until six weeks after Defendant's file an answer or six weeks after a hearing date for a motion to dismiss Plaintiff's First Amended Complaint to provide initial disclosures. (Washington, S)

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IRWIN M. ZALKIN, ESQ. (#89957)
DEVIN M. STOREY, ESQ. (#234271)
ALEXANDER S. ZALKIN, ESQ. (#280813)
RYAN M. COHEN, ESQ. (#261313)
JACQUELINE J. MCQUARRIE, ESQ. (#267319)
The Zalkin Law Firm, P.C.
12555 High Bluff Drive, Suite 301
San Diego, CA 92130
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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A.T., a minor, by and through his Guardian
ad Litem L.T.,

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Plaintiff,

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v.

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DRY CREEK JOINT ELEMENTARY
SCHOOL DISTRICT, PLACER COUNTY
OFFICE OF EDUCATION, PLACER
COUNTY CHILDREN SYSTEM OF
CARE, and the following individuals, who
are named in their individual capacities:
KD ASHTON, BECKY BRAVO, PETER
BALDO, LIZ LEE, CINDY STONE,
RENEE VERDUGO, MARY BOEHM,
CHRISTY CARTER, WENDY DEVORE,
DONNA KEARNS, LISA HEWITT,
TAMMY PETERSON, STEPHANIE
DILBECK, JEN ROGERS, VALERIE
MILLER, DAVID MOUL, DEBBIE
CANNON, JUDY BENNEY, REBECCA
RATEKIN, CARLEY ROSE JACKSON,
LAURI MCNALLY, SANDRA MOORE,
and DOES 1-30,

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Defendants.

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Civil Action No: 2:16-cv-02925-MCE-DB
JOINT STIPULATION AND ORDER
REGARDING EXTENSION OF TIME
TO FILE FIRST AMENDED
COMPLAINT AND FOR INITIAL
DISCLOSURES

[Demand for Jury Trial]

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED
COMPLAINT AND FOR INITIAL DISCLOSURES

IT IS HEREBY STIPULATED, that having received the Court’s order that Plaintiff has

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20 days from June 20, 2017 to file Plaintiff’s First Amended Complaint, Plaintiff will instead

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have 40 days from June 20, 2017 to file Plaintiff’s First Amended Complaint due to Plaintiff’s

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counsel going on vacation beginning June 21, 2017 and returning July 5, 2017, and due to

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Plaintiff’s counsel having approximately a two-week trial beginning on July 14, 2017 that

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Plaintiff’s counsel anticipates will proceed.
IT IS HEREBY FURTHER STIPULATED that Defendant Wendy DeVore, who was

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recently served with Plaintiff’s original Complaint on June 16, 2017, will be permitted to forego

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responding to Plaintiff’s original Complaint and instead will respond to Plaintiff’s First

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Amended Complaint.
IT IS HEREBY FURTHER STIPULATED that the parties will have until six weeks

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after Defendant’s file an answer or six weeks after a hearing date for a motion to dismiss

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Plaintiff’s First Amended Complaint to provide initial disclosures.

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Dated: June 20, 2017

THE ZALKIN LAW FIRM

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_/s/ Ryan M. Cohen____________________
IRWIN M. ZALKIN
DEVIN M. STOREY
ALEXANDER S. ZALKIN
RYAN M. COHEN
JACQUELINE J. MCQUARRIE
Attorneys for Plaintiff
A.T., a minor, by and through his Guardian Ad Litem,
L.T.

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Respectfully submitted,

Dated:

LOZANO SMITH
__/s/ Sloan R. Simmons__________________
SLOAN R. SIMMONS
KRISTY J. BOYES
Attorneys for Defendants
DRY CREEK ELEMENTARY SCHOOL DISTRICT,
PLACER COUNTY OFFICE OF EDUCATION, PETER
BALDO, JUDY BENNEY, MARY BOEHM, BECKY
BRAVO, DEBBIE CANNON, STEPHANIE DILLBECK,
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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED
COMPLAINT AND FOR INITIAL DISCLOSURES

LISA HEWITT, LIZ LEE, VALERIE MILLER,
SANDRA MOORE, CYNDI STONE, KD ASHTON,
CHRISTY CARTER,WENDY DEVORE, DONNA
KEARNS and JEN ROGERS

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Dated:

PLACER COUNTY COUNSEL’S OFFICE
_____/s/Julia M. Reeves_________________
JULIA M. REEVES
Attorneys for Defendants
PLACER COUNTY CHILDREN’S SYSTEM OF CARE,
RENEE VERDUGO, DAVID MOUL, LAURI
MCNALLY, CARLEY ROSE JACKSON, TAMMY
PETERSON and REBECCA RATEKIN

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED
COMPLAINT AND FOR INITIAL DISCLOSURES

ORDER

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Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY

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ORDERED, Plaintiff will have 40 days from June 20, 2017 to file Plaintiff’s First Amended

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Complaint (“FAC”). Plaintiff’s FAC shall therefore be filed no later than July 31, 2017.

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IT IS HEREBY FURTHER ORDERED that Defendant Wendy DeVore will be

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permitted to forego responding to Plaintiff’s original Complaint and instead will respond to

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Plaintiff’s First Amended Complaint.

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IT IS HEREBY FURTHER ORDERED that the parties will have until six weeks after

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Defendant’s file an answer or six weeks after a hearing date for a motion to dismiss Plaintiff’s

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First Amended Complaint to provide initial disclosures.
IT IS SO ORDERED.
Dated: July 6, 2017

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JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED
COMPLAINT AND FOR INITIAL DISCLOSURES