Donahue v. County of Sacramento

Filing 6

STIPULATION AND ORDER signed by District Judge Kimberly J. Mueller on 9/15/2017 ORDERING the plaintiff to file a First Amended Complaint by 10/13/2017; ORDERING Defendant County of Sacramento to respond to said complaint within 21 days thereafter. (Michel, G.)

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CREGGER & CHALFANT LLP
ROBERT L. CHALFANT, SBN 203051
Email: [e-mail]
701 University Avenue, Suite 110
Sacramento, CA 95825
Phone: [phone]
Fax: [phone]
Attorneys for Defendant COUNTY OF
SACRAMENTO

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LAW OFFICE OF VICKI E. CODY
VICKI E. CODY, SBN 157842
P. O. Box 189685
Sacramento, CA 95818-9685
Phone: [phone]
Fax: [phone]
Email:
[e-mail]
Attorney for Plaintiff LAMAR DONAHUE

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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LAMAR DONAHUE,

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Case No.: 2:17-cv-01842 KJM DB

Plaintiff,
vs.
COUNTY OF SACRAMENTO and DOES
1-25,

STIPULATION TO EXTEND TIME FOR
PLAINTIFF TO FILE A FIRST AMENDED
COMPLAINT; ORDER THEREON

Defendants.

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CREGGER & CHALFANT LLP
701 University Ave., #110
Sacramento, CA 95825
[phone]

WHEREAS, on February 21, 2017, Plaintiff filed a Complaint for Wrongful Detention, 42
U.S.C. Section 1983, Intentional Infliction of Emotional Distress in the Superior Court of the
State of California, Sacramento County, Action No. 34-2017-00208297;
WHEREAS, on August 9, 2017, Plaintiff served the Complaint on the Defendant County
of Sacramento by serving the Sacramento County Board of Supervisors;
WHEREAS, on September 6, 2017, Defendant County of Sacramento filed a removal of
this action to the U. S. District Court, Eastern District of California;
STIPULATION TO EXTEND TIME FOR PLAINTIFF
TO FILE FIRST AMENDED COMPLAINT; ORDER
Case No. 2:17-cv-01842 KJM DB

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WHEREAS, Defendant County of Sacramento’s response to the Complaint is due to be
filed by September 13, 2017;
WHEREAS, counsel for Defendant County of Sacramento and counsel for Plaintiff have

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met and conferred in an attempt to resolve issues prior to Defendant filing a motion to dismiss;

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WHEREAS, counsel for Plaintiff has agreed to file a First Amended Complaint;

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WHEREAS, in an attempt to avoid motions practice, counsel for the parties have agreed

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that Plaintiff’s counsel may have an extension of 30 days to October 13, 2017, within which to

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file a First Amended Complaint;

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WHEREAS, counsel for the parties have agreed that Defendant County of Sacramento

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may have 21 days after the filing of the First Amended Complaint to respond to the First

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Amended Complaint in any manner permitted under the Federal Rules of Civil Procedure;

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NOW THEREFORE, the parties through their attorneys stipulate as follows:

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1.

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Plaintiff may have an extension of 30 days to October 13, 2017, within which to

file a First Amended Complaint;
2.

Defendant County of Sacramento may have 21 days after the filing of the First

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Amended Complaint to respond to the First Amended Complaint in any manner permitted under

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the Federal Rules of Civil Procedure;

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IT IS SO STIPULATED.
DATE: September 13, 2017

CREGGER & CHALFANT LLP

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/s/ Robert L. Chalfant
ROBERT L. CHALFANT
Attorneys for Defendant COUNTY OF
SACRAMENTO

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DATE: September 13, 2017

LAW OFFICE OF VICKI E. CODY

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/s/ Vicki E. Cody
VICKI E. CODY
Attorney for Plaintiff LAMAR DONAHUE

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CREGGER & CHALFANT LLP
701 University Ave., #110
Sacramento, CA 95825
[phone]

STIPULATION TO EXTEND TIME FOR PLAINTIFF
TO FILE FIRST AMENDED COMPLAINT; ORDER
Case No. 2:17-cv-01842 KJM DB

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ORDER

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After considering the Stipulation by and between the parties through their counsel of
record, IT IS HEREBY ORDERED THAT:
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Plaintiff may have an extension of 30 days to October 13, 2017, within which to

file a First Amended Complaint; and
2.

Defendant County of Sacramento may have 21 days after the filing of the First

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Amended Complaint to respond to the First Amended Complaint in any manner permitted under

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the Federal Rules of Civil Procedure.

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IT IS SO ORDERED.

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DATED: September 15, 2017.

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UNITED STATES DISTRICT JUDGE

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CREGGER & CHALFANT LLP
701 University Ave., #110
Sacramento, CA 95825
[phone]

STIPULATION TO EXTEND TIME FOR PLAINTIFF
TO FILE FIRST AMENDED COMPLAINT; ORDER
Case No. 2:17-cv-01842 KJM DB

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