Robles v. County of Sacramento et al

Filing 9

STIPULATION and ORDER signed by District Judge John A. Mendez on 12/7/2017 GRANTING an Extension of Time for Defendant to respond to the complaint to 1/15/2017. (Hunt, G)

1
2

A PROFESSIONAL CORPORATION

5

Carl L. Fessenden, SBN 161494
John R. Whitefleet, SBN 213301
350 University Ave., Suite 200
Sacramento, California 95825
TEL: [phone]
FAX: [phone]

6

Attorneys for Defendant COUNTY OF SACRAMENTO

3
4

7

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

8
9

PABLO ROBLES,

10

Plaintiff,

PORTER | SCOTT

12
350 University Ave., Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

11

v.
COUNTY OF SACRAMENTO; SHERIFF
SCOTT JONES, in his official capacity,
DEPUTY HARDY (Badge No. 1434),
DEPUTY DANIEL (Badge No. 645),
DEPUTY MOVAHAN (Badge No. 452),
DEPUTY PAM (Badge No. 31), SGT. M.
LOPEZ (Badge No. 179), DEPUTY
MATOON (Badge No. 1095), OFFICER S.
ROBY (Badge No. 529), and Does 1-40,
inclusive,

13
14
15
16
17
18
19

CASE NO. 2:17-cv-01580-JAM-GGH

STIPULATION TO FURTHER EXTEND
TIME TO RESPOND TO COMPLAINT;
ORDER

Complaint Filed: 07/31/2017

Defendants.
___________________________________/

20
21

Plaintiff PABLO ROBLES, by and through his counsel of record, hereby agrees to extend

22

the time for Defendant COUNTY OF SACRAMENTO to respond to the Complaint of Plaintiff to

23

January 15, 2017. Good cause exists for this extension, as the individual defendants have not been

24

served, and Plaintiff continues to intend to amend the complaint which may include omitting

25

certain defendants, obviating the need to serve them and/or will narrow the scope of the suit, and

26

Plaintiff's counsel needs additional time to communicate with his client regarding the scope of the

27

amendments. Unfortunately, counsel for Plaintiff and Plaintiff temporarily lost contact due to his

28

incarceration and recently-discovered move to La Palma Correctional Facility in Eloy, Arizona,

1
STIPULATION TO FURTHER EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER

{01750101.DOCX}

1

and thus additional time is necessary to allow for the typically-delayed communications for out-of-

2

state incarcerated individuals.

3
4
5

Respectfully submitted,
Dated: December 7, 2017

A PROFESSIONAL CORPORATION

6

By /s/John R. Whitefleet_________________
John R. Whitefleet
Attorney for Defendant COUNTY OF
SACRAMENTO

7
8
9
10

PORTER SCOTT

Dated: December 7, 2017

LAW OFFICE OF KEVIN W. HARRIS

11
By /s/Kevin W. Harris (authorized on 12/7/17)
Kevin W. Harris
Attorney for Plaintiff

PORTER | SCOTT

350 University Ave., Suite 200
Sacramento, CA 95825
TEL: [phone]
FAX: [phone]

12
13
14

ORDER

15
16
17
18

GOOD CAUSE appearing, the Court hereby grants an extension of time for Defendant
COUNTY OF SACRAMENTO to respond to Plaintiffs’ complaint to January 15, 2017.
IT IS SO ORDERED.

19
20

Dated: 12/7/2017

21

/s/ John A. Mendez________________
John A. Mendez
U. S. District Court Judge

22
23
24
25
26
27
28

2
STIPULATION TO FURTHER EXTEND TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER

{01750101.DOCX}