Martinez et al v. Eastern Plumas Health Care Foundation, Inc.

Filing 18

STIPULATION and ORDER signed by District Judge John A. Mendez on 6/28/17, ORDERING that plaintiffs are GRANTED an additional two weeks, to 7/14/2017, to file a second amended complaint. (Kastilahn, A)

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HOYER & HICKS
Richard A. Hoyer (SBN 151931)
[e-mail]
Ryan L. Hicks (SBN 260284)
[e-mail]
Jennifer E. McGuire (SBN 282704)
[e-mail]
4 Embarcadero Center, Suite 1400
San Francisco, CA 94111
tel [phone]
fax [phone]
UNITED EMPLOYEES LAW GROUP, PC
Walter Haines (SBN 71075)
[e-mail]
5500 Bolsa Avenue, Suite 201
Huntington Beach, CA 92649
tel [phone]
fax [phone]
Attorneys for Plaintiffs
LISA TAYLOR, MICHELLE PEREZ,
MARIA MARINTEZ, and BARBARA NIEMINEN
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MICHELLE PEREZ, LISA TAYLOR, MARIA
MARTINEZ, and BARBARA NIEMINEN, on
behalf of themselves and all others similarly
situated,
Plaintiff,

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STIPULATION TO EXTEND TIME TO
FILE SECOND AMENDED
COMPLAINT AND ORDER THEREON

vs.
EASTERN PLUMAS HEALTH CARE
DISTRICT,

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Defendant.

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Case No. 2:17-cv-00674-JAM-EFB

STIPULATION
1.

Plaintiffs LISA TAYLOR, MICHELLE PEREZ, MARIA MARTINEZ, and

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BARBARA NIEMINEN (collectively, “Plaintiffs”), and EASTERN PLUMAS HEALTH CARE

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DISTRICT (“Defendant”) hereby agree as follows:

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2.

Plaintiffs served the Summons and First Amended Complaint (“FAC”) on

Defendant via mail on May 16, 2017. Defendant was not a named party to the original

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STIPULATION TO EXTEND TIME TO FILE
SECOND AMENDED COMPLAINT

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Complaint filed in this matter. Defendant did not receive the Summons and FAC until May

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18, 2017.

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3.

On June 13, 2017, the Court granted the parties’ stipulation and entered its

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order granting Plaintiffs leave to file a Second Amended Complaint (“SAC”) on or before

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June 30, 2017.

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4.

In the interest of avoiding motion practice regarding the forthcoming SAC, the

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parties hereby agree and stipulate to this request to extend the deadline for Plaintiffs to file

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the SAC an additional two weeks, to July 14, 2017.

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5.

Other than the express terms in this Stipulation, the Parties agree that this

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Stipulation shall not affect the rights or defenses of any party to this Stipulation, including

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Defendant’s right to seek remand, dismissal, or any other procedural or substantive relief,

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on any grounds, in response to the filing of the SAC.

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IT IS SO STIPULATED.

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Pursuant to Civil Local Rule 131(e), concurrence in the filing of this document has been

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obtained from Joseph Vidal Macias, Counsel for Defendant on June 27, 2017.

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HOYER & HICKS

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Date: June 27, 2017

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/s/ Ryan L. Hicks
Ryan Hicks
Attorney for Plaintiffs LISA TAYLOR,
MICHELLE PEREZ, MARIA MARTINEZ,
and BARBARA NIEMINEN

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SUTTON HAGUE LAW CORPORATION

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Date: June 27, 2017

/s/ Joseph Vidal Macias
Joseph Vidal Macias
Attorney for Eastern Plumas Health Care
District

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STIPULATION TO EXTEND TIME TO FILE
SECOND AMENDED COMPLAINT

ORDER

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Based upon the foregoing stipulation, and good cause appearing therefor, the terms
and conditions set forth in the stipulation are SO ORDERED.

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Dated: 6/28/2017
/s/ John A. Mendez____________
United States District Court Judge

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STIPULATION TO EXTEND TIME TO FILE
SECOND AMENDED COMPLAINT