Ramos v. Los Rios Community College District

Filing 6

STIPULATION AND ORDER signed by Senior Judge William B. Shubb on 8/4/2017 CONTINUING the Motion Hearing on 4 Motion to Dismiss to 10/16/2017 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb; ORDERING the plaintiff to file and serve an Opposition to said motion by 8/28/2017; ORDERING the defendant to file and serve its Reply by 9/11/2017. (Michel, G.)

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Alexis S. McKenna, Esq., SBN: 197120
Elana R. Jacobs, Esq., SBN: 303178
WINER, McKENNA & BURRITT, LLP
1999 HARRISON STREET, SUITE
600
OAKLAND, CALIFORNIA 94612
Tel [phone]
Fax [phone]
Attorneys for Plaintiff
ANGELA RAMOS

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION
ANGELA RAMOS, an individual;

Case No.: 2:17-cv-01458-WBS-KJN

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Plaintiff,

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v.
LOS RIOS COMMUNITY COLLEGE
DISTRICT, a public entity; THOMAS
KLOSTER dba METRO-MATH TUTORING
SERVICES, a company, THOMAS
KLOSTER, an individual; DOES 1-50,
inclusive,

STIPULATION AND ORDER TO
CONTINUE HEARING ON DEFENDANT
LOS RIOS COMMUNITY COLLEGE
DISTRICT’S RULE 12(b)(6) MOTION TO
DISMISS PLAINITFF’S COMPLAINT
Current Hearing Date:
Proposed Hearing Date:

August 21, 2017
October 16, 2017

Time:
Courtroom:

1:30 p.m.
5

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Defendants.
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Plaintiff Angela Ramos and Defendant Los Rios Community College District, by and

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through their undersigned counsel, hereby stipulate to continue the hearing on Defendant’s Rule

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12(b)(6) Motion to Dismiss Plaintiff’s Complaint. The hearing is currently scheduled for August 21,

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2017 at 1:30 p.m. and the parties hereby request that it be moved to October 16, 2017 at 1:30 p.m. in
Courtroom 5 in the above-referenced Court. Plaintiff’s counsel is unavailable on August 21, 2017
and requested that the parties stipulate to continue the hearing.
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STIPULATION AND [Proposed] ORDER TO CONTINUE HEARING ON DEFENDANT
LOS RIOS COMMUNITY COLLEGE DISTRICT’S RULE 12(b)(6) MOTION TO
DISMISS PLAINITFF’S COMPLAINT

The parties have further stipulated to the following briefing schedule: Plaintiff will file and

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serve her Opposition to Defendant’s Motion to Dismiss on or by August 28, 2017; Defendant will

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file and serve its Reply to Plaintiff’s Opposition to Defendant’s Motion to Dismiss on or by

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September 11, 2017. The Court to hear oral argument on the Motion on October 16, 2017.

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Counsel for the undersigned parties hereby submit this Stipulation and [Proposed] Order to
Continue Hearing pursuant to Eastern District of California Local Rule 143 (Fed. R. Civ. P. 83).

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SO STIPULATED.

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DATED: August 4, 2017

WINER, McKENNA & BURRITT, LLP

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By: /s/ Elana R.Jacobs___________________________.
Alexis S. McKenna
Elana R. Jacobs
Attorneys for Plaintiff
ANGELA RAMOS

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DATED: August 4, 2017

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JOHNSON SCHACHTER & LEWIS
A Professional Law Corporation

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By: /s/ Jason M. Sherman (as authorized on August 3, 2017)
Alesa Schachter
Jason M. Sherman
Attorneys for Defendant LOS RIOS COMMUNITY
COLLEGE DISTRICT

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STIPULATION AND [Proposed] ORDER TO CONTINUE HEARING ON DEFENDANT
LOS RIOS COMMUNITY COLLEGE DISTRICT’S RULE 12(b)(6) MOTION TO
DISMISS PLAINITFF’S COMPLAINT

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: August 4, 2017

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STIPULATION AND [Proposed] ORDER TO CONTINUE HEARING ON DEFENDANT
LOS RIOS COMMUNITY COLLEGE DISTRICT’S RULE 12(b)(6) MOTION TO
DISMISS PLAINITFF’S COMPLAINT