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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1 2 3 4 5 6 7 8 9 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: 858-259-3011 Fax: 858-259-3015 Email: Irwin@zalkin.com dms@zalkin.com alex@zalkin.com ryan@zalkin.com jackie@zalkin.com Attorneys for Plaintiff 10 11 UNITED STATES DISTRICT COURT 12 EASTERN DISTRICT OF CALIFORNIA 13 14 A.T., a minor, by and through his Guardian ad Litem L.T., 15 Plaintiff, 16 17 v. 18 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, 19 20 21 22 23 24 25 26 27 28 Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) 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] 1 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 1 2 20 days from June 20, 2017 to file Plaintiff’s First Amended Complaint, Plaintiff will instead 3 have 40 days from June 20, 2017 to file Plaintiff’s First Amended Complaint due to Plaintiff’s 4 counsel going on vacation beginning June 21, 2017 and returning July 5, 2017, and due to 5 Plaintiff’s counsel having approximately a two-week trial beginning on July 14, 2017 that 6 Plaintiff’s counsel anticipates will proceed. IT IS HEREBY FURTHER STIPULATED that Defendant Wendy DeVore, who was 7 8 recently served with Plaintiff’s original Complaint on June 16, 2017, will be permitted to forego 9 responding to Plaintiff’s original Complaint and instead will respond to Plaintiff’s First 10 Amended Complaint. IT IS HEREBY FURTHER STIPULATED that the parties will have until six weeks 11 12 after Defendant’s file an answer or six weeks after a hearing date for a motion to dismiss 13 Plaintiff’s First Amended Complaint to provide initial disclosures. 14 15 Dated: June 20, 2017 THE ZALKIN LAW FIRM 16 _/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. 17 18 19 20 21 22 23 24 25 26 27 28 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, 2 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 1 2 3 4 5 6 7 8 9 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 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED COMPLAINT AND FOR INITIAL DISCLOSURES ORDER 1 2 Pursuant to the stipulation of the parties and good cause appearing, IT IS HEREBY 3 ORDERED, Plaintiff will have 40 days from June 20, 2017 to file Plaintiff’s First Amended 4 Complaint (“FAC”). Plaintiff’s FAC shall therefore be filed no later than July 31, 2017. 5 IT IS HEREBY FURTHER ORDERED that Defendant Wendy DeVore will be 6 permitted to forego responding to Plaintiff’s original Complaint and instead will respond to 7 Plaintiff’s First Amended Complaint. 8 IT IS HEREBY FURTHER ORDERED that the parties will have until six weeks after 9 Defendant’s file an answer or six weeks after a hearing date for a motion to dismiss Plaintiff’s 10 11 12 First Amended Complaint to provide initial disclosures. IT IS SO ORDERED. Dated: July 6, 2017 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 JOINT STIPULATION AND ORDER REGARDING EXTENSION OF TIME TO FILE FIRST AMENDED COMPLAINT AND FOR INITIAL DISCLOSURES

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