Doe v. San Joaquin County et al

Filing 33

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 6/13/2019 EXTENDING Time through and including 8/19/2019, for Defendants to File Response to 31 First Amended Complaint. (York, M)

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Gregory B. Thomas (SBN 239870)
E-mail: [e-mail]
Temitayo O. Peters (SBN 309913)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
1901 Harrison Street, Suite 900
Oakland, CA 94612-3501
Tel: [phone] Fax: [phone]

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Attorneys for Defendant
DANNY SWANSON

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JANE DOE,

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Case No. 2:18-cv-00667-TLN-AC
Plaintiff,

v.

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SAN JOAQUIN COUNTY, SHERIFF
STEVE MOORE, DANNY SWANSON
AND DOES 1-25,

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSE TO FIRST AMENDED
COMPLAINT

Defendants.

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[Civ. L. Rule 144; Fed. R. Civ. P. 6]

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Pursuant to Eastern District Civil Local Rule 144, and Federal Rule of Civil Procedure 6,

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Plaintiff Jane Doe (“Plaintiff”) and Defendants San Joaquin County, Sheriff Steve Moore and

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Danny Swanson (collectively “Defendants”), by and through their attorneys of record, hereby

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stipulate to an extension of time for Defendants to move, plead, or otherwise respond to

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Plaintiff’s First Amended Complaint, as follows:

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On June 9, 2019, Plaintiff filed a First Amended Complaint against Defendants

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alleging various federal constitutional and state law claims in the United States District Court for

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the Eastern District of California (2:18-cv-00667-TLN-AC).

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2.

Under Federal Rule of Civil Procedure 15(a)(3), Defendants currently must file

their responses to the First Amended Complaint by June 24, 2019.
3.

Plaintiff and Defendants are scheduled to mediate this matter on August 5, 2019, at

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
OAKLAND

OAK #4826-4919-7977 v1

STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSIVE PLEADINGS

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ADR Services in Oakland, California, to attempt to resolve the lawsuit.
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Mediation may obviate the need for Defendants to file a response to the First

Amended Complaint.
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On June 10, 2019, Plaintiff and Defendants, through their respective counsel of

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record, met and conferred regarding the suitability of extending Defendants’ time to respond to

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the First Amended Complaint pending the outcome of mediation under Eastern District Civil

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Local Rule 144 and Federal Rule of Civil Procedure 6.
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beyond the scheduled mediation date, would exceed the twenty-eight (28) days allowed under
Eastern District Civil Local Rule 144 without Court approval.
7.

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This is the first stipulation for an extension of time to file a response to the First

Amended Complaint.
Based on the foregoing, IT IS HEREBY STIPULATED, by and between all parties

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An appropriate extension of time to respond to the First Amended Complaint,

through their respective counsel of record, that:
(1)

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Defendants San Joaquin County and Sheriff Steve Moore’s deadline to move,

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plead, or otherwise respond to the First Amended Complaint is extended through and including

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August 19, 2019.

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
OAKLAND

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSIVE PLEADINGS

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(2)

Defendant Danny Swanson’s deadline to move, plead, or otherwise respond to the

First Amended Complaint is extended through and including August 19, 2019.
IT IS SO STIPULATED.

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Dated: June 13, 2019

BURKE, WILLIAMS & SORENSEN, LLP

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By: /s/ Gregory B. Thomas, Esq.
Gregory B. Thomas
Temitayo O. Peters
Attorneys for Defendant
DANNY SWANSON

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Dated: June 13, 2019

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By: /s/ Stanley Goff, Esq. (authorization
obtained via email on 6/13/19)
Stanley Goff, Esq.
Attorneys for Plaintiff
JANE DOE

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Dated: June 13, 2019

HERUM CRABTREE SUNTAG

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By: /s/ Dana A. Suntag, Esq. (authorization
obtained via email on 6/13/19)
Dana A. Suntag, Esq.
Attorneys for Defendants
SAN JOAQUIN COUNTY and SHERIFF
STEVE MOORE

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
OAKLAND

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSIVE PLEADINGS

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ORDER EXTENDING TIME TO FILE
RESPONSE TO PLAINTIFF’S FIRST AMENDED COMPLAINT

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IN CONSIDERATION of the parties’ Stipulation extending Defendants’ time to file a

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response to Plaintiff’s First Amended Complaint, and for good cause shown therein, it is

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ORDERED that Defendants’ deadline to move, plead, or otherwise respond to Plaintiff’s First

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Amended Complaint is extended from July 1, 2019 through and including August 19, 2019.

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Dated: June 13, 2019

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Troy L. Nunley
United States District Judge

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
OAKLAND

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STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSIVE PLEADINGS