Shekarlab v. County of Sacramento et al

Filing 15

STIPULATION and ORDER signed by District Judge John A. Mendez on 2/23/2018 ORDERING that Defendant Robert Padilla shall file a responsive pleading on or before March 26, 2018. (Becknal, R)

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R IV E R A & A S S O C IAT E S

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1425 River Park Drive, Suite 250
Sacramento, California 95815

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Tel: [phone] Fax: [phone]

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Jesse M . Rivera, SBN 84259
Shanan L. Hewitt, SBN 200168

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Jonathan B. Paul, SBN 215884
Jill B. Nathan, SBN 186136

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Glen A. W illiams, SBN 257665

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Attorneys for Defendant,
Robert Padilla, M.D.

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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Plaintiff,
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vs.
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COUNTY OF SACRAMENTO; ROBERT )
PADILLA, M.D.; CHARLES KIM, M.D. )
MAJEET KAUR, R.N. JOYCE AMAJOR, )
R.N. KATHRYN GONZALES, and DOES )
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Defendants.
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CASE NO. 2:18-CV-00047-JAM-EFB

RAMIN A. SHEKARLAB,

STIPULATION AND ORDER FOR
EXTENSION OF TIME TO RESPOND
TO COMPLAINT

[E.D. Cal. L.R. 144(a)]

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Plaintiff Ramin A. Shekarlab (“Plaintiff”) and Defendants County of Sacramento and Robert

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Padilla (“Defendants”) by and through their respective counsel of record, hereby stipulate and agree

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as follows:

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Whereas, this Court previously issued an order extending the response pleading deadline for

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all defendants from February 9, 2018 to February 23, 2018.

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Whereas, counsel for Defendant Padilla did not receive assignment of the defense of this

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case until February 22, 2018.

Stipulation and [Proposed] Order Re Defendant Padilla’s Extension of Time to File a Responsive Pleading
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Whereas, Defendant Padilla is on medical leave and unable to travel to defense counsel’s

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office at this time.

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Whereas, Defendant Padilla has not had sufficient time to investigate the factual allegations

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of the complaint herein.

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Whereas, in light of the foregoing facts and upon order of the Court, THE PARTIES

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HEREBY STIPULATE that:

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1.

Defendant Robert Padilla may file a responsive pleading to Plaintiff’s complaint on

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or before March 26, 2018.

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IT IS SO STIPULATED.

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DATED: February 23, 2018

LAW OFFICES OF STEWART KATZ

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/s/ Stewart Katz (as authorized on 02/23/18)

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Stewart Katz
Attorney for Plaintiff
Ramin A. Shekarlab

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DATED: February 23, 2018

LONGYEAR, O’DEA & LAVRA, LLP

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/s/ Van Longyear (as authorized on 02/23/18)

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Van Longyear
Attorney for Defendant
County of Sacramento

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DATED: February 23, 2018

LAW OFFICES OF RIVERA & ASSOCIATES

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/s/ Jonathan B. Paul

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Jonathan B. Paul
Attorney for Defendant
Robert Padilla

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ORDER

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By stipulation of the parties and good cause appearing, it is hereby ordered that:
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1. Defendant Robert Padilla shall file a responsive pleading on or before March 26, 2018.
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DATED: February 23, 2018

/s/ John A. Mendez
HONORABLE JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

Stipulation and [Proposed] Order Re Defendant Padilla’s Extension of Time to File a Responsive Pleading
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