Mkrtchyan v. Sacramento County et al

Filing 8

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 1/4/2018 ORDERING that Defendant, County of Sacramento, may have an EXTENSION of time up to and including February 2, 2018, within which to file a Responsive pleading to Plaintiff's First Amended Complaint; in any manner permitted under the Federal Rules of Civil Procedure. (Becknal, R)

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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
Patrick H. Dwyer, SBN 137743
P.O. Box 1705
Penn Valley, CA 95946
Grass Valley, CA 95949
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff ARAM MKRTCHYAN

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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ARAM MKRTCHYAN, an individual,

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Plaintiff,

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vs.
SACRAMENTO COUNTY,
CALIFORNIA, a county government and
the operator of the Sacramento County
Sheriff’s Department and its Correctional
Health Services Division; and the
following persons as individual and in their
capacity as officials, employees or
contractors of Sacramento County: R.
SCOTT JONES; GRANT NUGENT;
DEPUTY DOMINGUEZ; DEPUTY
YANG; DEPUTY GROUT; DEPUTY
MEIER; and DOES 1-40, inclusive,

Case No.: 2:17-CV-2366-TLN-KJN
STIPULATION TO EXTEND TIME TO
DEFENDANT COUNTY OF
SACRAMENTO TO FILE A RESPONSIVE
PLEADING TO FIRST AMENDED
COMPLAINT AND; ORDER THEREON

Defendants.

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WHEREAS, on December 5, 2017, Plaintiff filed a First Amended Civil Complaint for

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Damages in the United Stated District Court for the Eastern District of California, Sacramento,

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Case, No.: 2:17-CV-2366-TLN-KJN;

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

STIPULATION AND ORDER TO EXTEND TIME FOR
DEFENDANT COUNTY OF SACRAMENTO TO FILE
RESPONSIVE PLEADING
Case No. 2:17-CV-2366-TLN-KJN

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WHEREAS, on December 11, 2017, Plaintiff served the First Amended Civil Complaint
on the County of Sacramento;

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WHEREAS, on December 28, 2017, the County of Sacramento retained Robert Chalfant
as lead defense counsel in this matter;

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WHEREAS, Defendant County of Sacramento’s response to the Complaint was due to be
filed by January 2, 2018;

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WHEREAS, there is currently a dispute as to whether Plaintiff properly served
Defendants in this matter;

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WHEREAS, in order to resolve the dispute regarding service, Counsel for the County of
Sacramento has agreed to seek authorization to waive service from each of the named defendants;

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WHEREAS, resolving the service issues would allow one responsive pleading to be filed,
instead of several being filed at different times;

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WHEREAS, counsel for Defendant County of Sacramento and Plaintiff have met and
conferred in an attempt to resolve these issues prior to Defendant filing a motions to quash or
dismiss;

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WHEREAS, in an attempt to avoid motions practice, counsel have agreed that the County
of Sacramento may have an extension of time up to and including February 2, 2018, within which
to file its Responsive pleading, in any manner permitted under the Federal Rules of Civil
Procedure;

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NOW THEREFORE, the parties by way of their attorneys stipulate as follows:

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1.

Defendant County of Sacramento may have an extension of time up to and

including February 2, 2018, within which to file its Responsive pleading to the First Amended
Complaint in any manner permitted under the Federal Rules of Civil Procedure.
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CREGGER & CHALFANT LLP
701 University Ave., #110
Sacramento, CA 95825
[phone]

STIPULATION AND ORDER TO EXTEND TIME FOR
DEFENDANT COUNTY OF SACRAMENTO TO FILE
RESPONSIVE PLEADING
Case No. 2:17-CV-2366-TLN-KJN

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IT IS SO STIPULATED.
DATE: January 3, 2018

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: January 3, 2018

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/s/Patrick H. Dwyer
PATRICK H. DWYER
Attorney for Plaintiff ARAM MKRTCHYAN

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ORDER
After considering the Stipulation by and between the parties through their counsel of
record, IT IS HEREBY ORDERED THAT:
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Defendant, County of Sacramento, may have an extension of time up to and

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including February 2, 2018, within which to file a Responsive pleading to Plaintiff’s First

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

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IT IS SO ORDERED.

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Dated: January 4, 2018

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Troy L. Nunley
United States District Judge

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

STIPULATION AND ORDER TO EXTEND TIME FOR
DEFENDANT COUNTY OF SACRAMENTO TO FILE
RESPONSIVE PLEADING
Case No. 2:17-CV-2366-TLN-KJN

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