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)

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1 K&G LAW LLC LAURA A. GENOVESE (Admitted Pro Hac Vice) 2 lgenovese@kassgen.com 602 South Bethlehem Pike 3 Building B, Second Floor Ambler, Pennsylvania 19002 4 Telephone: (267) 468-7961 5 Facsimile: (267) 468-7140 6 WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP DANIEL L. BAXTER (SBN 203862) 7 dbaxter@wilkefleury.com 400 Capitol Mall, Twenty-Second Floor 8 Sacramento, California 95814 9 Telephone: (916) 441-2430 Facsimile: (916) 442-6664 10 Attorneys for Defendant 11 PRIMITIVES BY KATHY, INC. 12 13 UNITED STATES DISTRICT COURT 14 EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION 15 16 CHRISTINE N. TRICE, Case No. 2:17-CV-00586-TLN-CKD 17 SECOND STIPULATION AND ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT, AND RELATED DEADLINES Plaintiff, 18 v. 19 PRIMITIVES BY KATHY, INC., and DOES 1 to 10, inclusive, 20 Defendants. 21 Complaint Filed: March 20, 2017 Trial Date: Not Yet Set 22 RECITALS 23 On May 16, 2017, the Court—pursuant to the stipulation of Plaintiff CHRISTINE N. TRICE 24 25 26 27 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. 28 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 1 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. 9 STIPULATION 10 Pursuant to Local Rule 144(a), the parties, by and through their duly-authorized attorneys, 11 HEREBY STIPULATE AND AGREE as follows: 12 1. Defendant shall have an additional thirty (30) days in which to respond to the The initial deadline for Defendant’s response 13 Complaint filed in this matter. 14 (following Defendant’s waiver of service under Federal Rule of Civil Procedure 4(d)) 15 was May 19, 2017, with a prior extension granted to June 19, 2017; pursuant to the 16 instant stipulation, the new deadline for Defendant to file and serve its response to 17 Plaintiff’s Complaint shall be July 19, 2017, inclusive. 18 2. The deadline for the parties to confer as required by Federal Rule of Civil Procedure 19 26(f) and Paragraph 4 of the Court’s aforementioned Order Requiring Joint Status 20 Report shall be continued to August 18, 2017, inclusive. 21 3. The deadline for the parties to prepare and submit the Joint Status Report required by 22 Paragraph 4 of the Court’s aforementioned Order Requiring Joint Status Report shall 23 be continued to August 18, 2017, inclusive. 24 4. 25 The deadline for the parties to exchange their Initial Disclosures shall be continued to September 1, 2017, inclusive. 26 27 [Signatures on Next Page] 28 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. 1 SO STIPULATED. 2 DATED: June 21, 2017 3 WILKE, FLEURY, HOFFELT, GOULD & BIRNEY, LLP 4 5 By: /s/ Daniel L. Baxter DANIEL L. BAXTER Attorneys for Defendant PRIMITIVES BY KATHY, INC. 6 7 8 9 DATED: June 21, 2017 DICKENSON PEATMAN & FOGARTY P.C. 10 11 12 By: /s/ Christopher J. Passarelli CHRISTOPHER J. PASSARELLI Attorneys for Plaintiff CHRISTINE N. TRICE 13 14 15 ORDER 16 17 IT IS SO ORDERED. 18 19 Dated: June 21, 2017 20 Troy L. Nunley United States District Judge 21 22 23 24 25 26 27 28 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.

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