Trice v. Primitives by Kathy, Inc.

Filing 10

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 5/16/2017 ORDERING that defendant shall have an additional thirty-one days in which to respond to the complaint. The new deadline for Defendant to file and serve its response to plaintiff's complaint is 6/19/2017. The deadline for the parties to confer is CONTINUED to 7/21/2017. The deadline for the parties to submit the Joint Status Report is CONTINUED to 7/21/2017. The deadline for the parties to exchange their Initial Disclosures is CONTINUED to 8/4/2017. (Zignago, K.)

1 K&G LAW LLC
LAURA A. GENOVESE (Admitted Pro Hac Vice)
2 [e-mail]
602 South Bethlehem Pike
3 Building B, Second Floor
Ambler, Pennsylvania 19002
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Telephone:
[phone]
5 Facsimile:
[phone]
6 WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP
DANIEL L. BAXTER (SBN 203862)
7 [e-mail]
400 Capitol Mall, Twenty-Second Floor
8 Sacramento, California 95814
9 Telephone:
[phone]
Facsimile:
[phone]
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Attorneys for Defendant
11 PRIMITIVES BY KATHY, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

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16 CHRISTINE N. TRICE,

Case No. 2:17-CV-00586-TLN-CKD

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND TO
COMPLAINT, AND RELATED
DEADLINES

Plaintiff,

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v.

19 PRIMITIVES BY KATHY, INC., and DOES
1 to 10, inclusive,
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Defendants.
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Complaint Filed: March 20, 2017
Trial Date:
Not Yet Set

RECITALS

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In the captioned action, Plaintiff CHRISTINE N. TRICE and Defendant PRIMITIVES BY

24 KATHY, INC. have recently initiated settlement discussions that may result in a resolution of the
25 case. In order to fully accommodate those settlement discussions in a manner that avoids potentially
26 unnecessary court filings, the parties wish to extend the current deadline for Defendant to respond to
27 Plaintiff’s Complaint for a period of 31 days, and to continue the Rule 26-related deadlines specified
28 in the Court’s Order Requiring Joint Status Report (CM/ECF Doc. No. 3) for a like period.
W ILK E , F LEURY ,
H O FFELT , G O ULD &
B IRNEY , LLP
ATTOR NE YS

AT

LAW

SACRA ME NTO

1597465.1

2:17-CV-00586-TLN-CKD
STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.

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STIPULATION

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Pursuant to Local Rule 144(a), the parties, by and through their duly-authorized attorneys,

3 HEREBY STIPULATE AND AGREE as follows:
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1.

Defendant shall have an additional thirty-one (31) days in which to respond to the
The initial deadline for Defendant’s response

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Complaint filed in this matter.

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(following Defendant’s waiver of service under Federal Rule of Civil Procedure 4(d))

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is May 19, 2017; pursuant to the instant stipulation, the new deadline for Defendant to

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file and serve its response to Plaintiff’s Complaint shall be June 19, 2017, inclusive.

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2.

The deadline for the parties to confer as required by Federal Rule of Civil Procedure

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26(f) and Paragraph 4 of the Court’s aforementioned Order Requiring Joint Status

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Report shall be continued to July 21, 2017, inclusive.

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3.

The deadline for the parties to prepare and submit the Joint Status Report required by

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Paragraph 4 of the Court’s aforementioned Order Requiring Joint Status Report shall

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be continued to July 21, 2017, inclusive.

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4.

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The deadline for the parties to exchange their Initial Disclosures shall be continued to
August 4, 2017, inclusive.

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SO STIPULATED.

18 DATED: May 16, 2017
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WILKE, FLEURY, HOFFELT,
GOULD & BIRNEY, LLP

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By:

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/s/ Daniel L. Baxter
DANIEL L. BAXTER
Attorneys for Defendant
PRIMITIVES BY KATHY, INC.

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[Additional Signatures on Next Page]

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W ILK E , F LEURY ,
H O FFELT , G O ULD &
B IRNEY , LLP
ATTOR NE YS

AT

LAW

SACRA ME NTO

1597465.1

2:17-CV-00586-TLN-CKD
-1STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.

1 DATED: May 16, 2017

DICKENSON PEATMAN & FOGARTY P.C.

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By:

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/s/ Christopher J. Passarelli
CHRISTOPHER J. PASSARELLI
Attorneys for Plaintiff
CHRISTINE N. TRICE

ORDER

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IT IS SO ORDERED.

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10 Dated: May 16, 2017
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Troy L. Nunley
United States District Judge

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W ILK E , F LEURY ,
H O FFELT , G O ULD &
B IRNEY , LLP
ATTOR NE YS

AT

LAW

SACRA ME NTO

1597465.1

2:17-CV-00586-TLN-CKD
-2STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.