Barai v. California Department of State Hospitals - Stockton et al

Filing 6

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 1/13/17: The time in which Defendants shall file a responsive pleading to Plaintiff's Complaint for Damages and Injunctive Relief be extended for 14 days to January 26, 2017. (Kaminski, H)

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KATHLEEN A. KENEALY, State Bar No. 212289
Acting Attorney General of California
SUSAN E. SLAGER, State Bar No. 162942
Supervising Deputy Attorney General
CATHERINE E. FLORES, State Bar No. 252240
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
California Department of State Hospitals – Stockton,
and Juan C. Arguello

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SHARMISTHA BARAI, an individual,

2:16-CV-02995-KJM-CKD

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v.

Plaintiff, JOINT REQUEST FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT;
ORDER

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[E.D. Cal. Local R. 144(a)]
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CALIFORNIA DEPARTMENT OF STATE
HOSPITALS - STOCKTON, a public
agency; JUAN C. ARGUELLO, an
individual; and DOES 1-100, inclusive,
Action Filed: October 24, 2016
Defendants. Notice of Removal Filed: December 22, 2016

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JOINT REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Plaintiff Sharmistha Barai, an individual, and Defendants California Department of State

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Hospitals – Stockton, a public agency, and Juan C. Arguello, an individual, through their

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respective counsels of record, hereby stipulate as follows:

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A. WHEREAS, Defendants filed a Notice of Removal on December 22, 2016.

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REQUEST FOR EXT. OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER (2:16-CV-02995-KJM-CKD)

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B. WHEREAS, on December 29, 2016, the parties entered into and filed an initial

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stipulation to a 14-day extension of time in which the Defendants would have to respond to the

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Complaint, in order to facilitate the parties’ meet and confer efforts.

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C. WHEREAS, the parties now request additional time to continue their meet and confer
efforts and allow Plaintiff to file a First Amended Complaint.

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NOW, THEREFORE, Plaintiff and Defendants stipulate that:

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It is in the interest of judicial economy to extend the time in which Defendants may

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respond to Plaintiff’s Complaint for Damages and Injunctive Relief be extended for 14 days to

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January 26, 2017.

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IT IS SO STIPULATED THROUGH COUNSEL OF RECORD.

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Dated: January 12, 2017

Respectfully submitted,
KATHLEEN A. KENEALY
Acting Attorney General of California
SUSAN E. SLAGER
Supervising Deputy Attorney General

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/s/ Catherine E. Flores

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CATHERINE E. FLORES
Deputy Attorney General
Attorneys for Defendants
California Department of State Hospitals –
Stockton, and Juan C. Arguello

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Dated: January 12, 2017

CRAWFORD LAW GROUP
/s/ Daniel A. Crawford
(as authorized on January 11, 2017)

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ROZA CRAWFORD
DANIEL A. CRAWFORD
Attorneys for Plaintiff Sharmistha Barai

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REQUEST FOR EXT. OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER (2:16-CV-02995-KJM-CKD)

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ORDER
PURSUANT TO STIPULATION BY THE PARTIES TO THIS CASE, IT IS HEREBY
ORDERED THAT:
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The time in which Defendants shall file a responsive pleading to Plaintiff’s

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Complaint for Damages and Injunctive Relief be extended for 14 days to January 26, 2017.

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DATED: January 13, 2017.

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UNITED STATES DISTRICT JUDGE

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REQUEST FOR EXT. OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER (2:16-CV-02995-KJM-CKD)