Coleman v. Placer County et al

Filing 30

AMENDED STIPULATION and ORDER signed by Senior Judge William B. Shubb on 11/21/2017 for an Extension of Time through 12/7/2017, for Defendants to Amend 20 , 21 , and 22 Answers to 1 Complaint. (York, M) Modified on 11/22/2017 (York, M).

1 PLACER COUNTY COUNSEL’S OFFICE
Brett D. Holt (SBN: 133525)
2 [e-mail]
Julia M. Reeves (SBN: 241198)
3 [e-mail]
175 Fulweiler Avenue
4 Auburn, CA 95603
Telephone: [phone]
5 Facsimile: [phone]
6 Blake P. Loebs (SBN: 145790)
[e-mail]
7 David Mehretu (SBN: 269398)
[e-mail]
8 Robert S. Moutrie (SBN: 295250)
[e-mail]
9 MEYERS, NAVE, RIBACK, SILVER & WILSON
555 12th Street, Suite 1500
10 Oakland, California 94607
Telephone: [phone]
11 Facsimile: [phone]
12
Attorneys for Defendants PLACER COUNTY,
13 DEVON BELL, JEREMY BURCH, DAN
CUNNINGHAM, AUBREY HARRIS,
14 MATTHEW SPENCER, MACKENZIE
MILLER, R. SCOTT OWENS, BENJAMIN
15 EGGERT and JENNIFER MISZKEWYCZ
16

UNITED STATES DISTRICT COURT

17

EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

18 BRENDAN COLEMAN, an individual,

Case No. 2:17-CV-01579-WBS-CKD

19

AMENDED STIPULATION AND
PROPOSED ORDER EXTENDING TIME
TO AMEND ANSWER TO THE
COMPLAINT

Plaintiff,

20 v.
21 PLACER COUNTY, CALIFORNIA, a county
government, and the following persons as
22 individuals and in their capacity as officials,
employees or contractors of PLACER
23 COUNTY: DEVON BELL, ROBERT
MADDEN, MEGAN YAWS, JEREMY
24 BURCH, DAN CUNNINGHAM, AUBREY
HARRIS, MATTHEW SPENCER,
25 MACKENZIE MILLER, R. SCOTT OWENS,
BENJAMIN EGGERT, JENNIFER
26 MISZKEWYCZ and DOES 1 through 30,
27

Defendants.

28

AMENDED STIPULATION & PROPOSED ORDER EXTENDING TIME TO AMEND ANSWER

1

Defendants Placer County, Devon Bell, Jeremy Burch, Dan Cunningham, Aubrey Harris,

2 Matthew Spencer, Mackenzie Miller, R. Scott Owens, Benjamin Eggert, Jennifer Miszkewycz,
3 Robert Madden, and Megan Yaws (“Defendants”) and Plaintiff Brendan Coleman (“Plaintiff”)
4 seek an order from this Court to extend the deadline for Defendants to file amended Answers to
5 Plaintiff’s Complaint by twenty-one (21) days or for Plaintiff to file a motion to strike under
6 FRCP 12(f). The parties are in the process of meeting and conferring regarding the sufficiency of
7 the Defendants’ Answers and also in discussion regarding potential settlement. The parties wish
8 to allow time for both discussions to fully resolve and leave the Defendants time to potentially
9 amend their Answers after such discussion, if they so choose.
10

The Parties seek the Court’s approval of a twenty-one (21) day extension, for good cause

11 and the convenience of the parties, extending Defendants’ deadline to amend their answer to
12 Plaintiff’s Complaint from November 16, 2017, until December 7, 2017.
13
14 DATED: November 16, 2017

MEYERS, NAVE, RIBACK, SILVER & WILSON

15
By: /s/ Robert S. Moutrie
Robert S. Moutrie
Attorneys for Defendants PLACER COUNTY,
DEVON BELL, JEREMY BURCH; DAN
CUNNINGHAM, AUBREY HARRIS,
MATTHEW SPENCER, MACKENZIE MILLER,
R. SCOTT OWENS, BENJAMIN EGGERT and
JENNIFER MISZKEWYCZ

16
17
18
19
20
DATED: November 16, 2017

LAW OFFICE OF PATRICK H. DWYER

21
22
23

By: /s/ Patrick H. Dwyer (as authorized on 11/16/17)
Patrick H. Dwyer
Attorneys for Plaintiff
BRENDAN COLEMAN

24
25
26
27
28
1
AMENDED STIPULATION & PROPOSED ORDER EXTENDING TIME TO AMEND ANSWER

1 DATED: November 16, 2017

ANGELO, KILDAY & KILDUFF

2
By: /s/ Brue Kilday (as authorized on 11/16/17)
Bruce Kilday
Attorneys for Defendant
ROBERT MADDEN

3
4
5
DATED: November 16, 2017

RIVERA AND ASSOCIATES

6
7
8

By: /s/ Jonathan Paul (as authorized on 11/16/17)
Jonathan Paul
Attorneys for Defendant
MEGAN YAWS

9
Attestation of Concurrence in the Filing
10
11

The filer, Robert S. Moutrie, attests that all other signatories listed on whose behalf this

12 filing is submitted concur in the filing’s content and have authorized the filing.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
2
AMENDED STIPULATION & PROPOSED ORDER EXTENDING TIME TO AMEND ANSWER

1
2

ORDER
All Defendants may have an additional twenty-one (21) days to amend their answer to

3 Plaintiff’s Complaint. The deadline for Defendants to amend their answer is extended until
4 December 7, 2017.
5

IT IS SO ORDERED.

6 Dated: November 21, 2017
7
8
9
2890889.1

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
3
AMENDED STIPULATION & PROPOSED ORDER EXTENDING TIME TO AMEND ANSWER