Trice v. Primitives by Kathy, Inc.

Filing 12

SECOND STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/21/17. Defendant shall have an additional thirty (30) days in which to respond to the Complaint filed in this matter. The new deadline shall be 7/19/2017. The deadline for the parties to confer shall be continued to 8/18/17. inclusive. The deadline for the parties to prepare and submit the Joint Status Report shall be continued to 8/18/17, inclusive. The deadline for the parties to exchange their Initial Disclosures shall be continued to 9/1/2017, inclusive. (Mena-Sanchez, L)

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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SECOND 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

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RECITALS
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On May 16, 2017, the Court—pursuant to the stipulation of Plaintiff CHRISTINE N. TRICE
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and Defendant PRIMITIVES BY KATHY, INC—entered an order continuing Defendant’s deadline
to respond to Plaintiff’s Complaint filed herein, and additionally extended certain related deadlines
pertaining to the parties’ Joint Status Report and Initial Disclosures. (CM/ECF Doc. No. 10.) Per that
stipulation and order, Defendant’s deadline to respond to Plaintiff’s Complaint falls on June 19, 2017.

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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

1614827.1

2:17-CV-00586-TLN-CKD

SECOND STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.

Since the Court’s entry of its order, the parties continue to engage in intensive settlement

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2 negotiations that they believe will likely resolve the case. Unfortunately, those negotiations have not
3 yet produced a final agreement. Hence, in the hopes of concluding their negotiations without the need
4 to submit imminent court filings, the parties wish to secure one further and final 30-day extension for
5 Defendant to respond to Plaintiff’s Complaint, and to continue the Rule 26-related deadlines specified
6 in the Court’s Order Requiring Joint Status Report (CM/ECF Doc. No. 3) for a like period. Should a
7 full settlement not be forthcoming within that additional 30-day time period, Defendant will file its
8 response in accordance with the new deadline, with no further extension requests.
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STIPULATION

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

11 HEREBY STIPULATE AND AGREE as follows:
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1.

Defendant shall have an additional thirty (30) 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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was May 19, 2017, with a prior extension granted to June 19, 2017; pursuant to the

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instant stipulation, the new deadline for Defendant to file and serve its response to

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Plaintiff’s Complaint shall be July 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 August 18, 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 August 18, 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
September 1, 2017, inclusive.

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[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

1614827.1

-1-

2:17-CV-00586-TLN-CKD

SECOND STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.

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SO STIPULATED.

2 DATED: June 21, 2017
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WILKE, FLEURY, HOFFELT,
GOULD & BIRNEY, LLP

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By:

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

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DATED: June 21, 2017

DICKENSON PEATMAN & FOGARTY P.C.

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By:

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

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ORDER

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IT IS SO ORDERED.

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Dated: June 21, 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

1614827.1

-2-

2:17-CV-00586-TLN-CKD

SECOND STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, ETC.