Doe v. San Joaquin County et al

Filing 35

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 8/7/2019 EXTENDING Defendants' deadline to respond to 31 First Amended Complaint to 11/18/2019. (Huang, H)

1
2
3
4
5

DANA A. SUNTAG (State Bar No. 125127)
JOSHUA J. STEVENS (State Bar No. 238105)
HERUM\CRABTREE\SUNTAG
A California Professional Corporation
5757 Pacific Avenue, Suite 222
Stockton, California 95207
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

6
7
8

Attorneys for Defendants
THE COUNTY OF SAN JOAQUIN and
SHERIFF STEVE MOORE

9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11

JANE DOE,

12
13
14
15
16
17
18
19
20

Plaintiff,
vs.
SAN JOAQUIN COUNTY; SHERIFF
STEVE MOORE, DANNY SWANSON,
and DOES 1 through 25,
Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:18-cv-00667-TLN-AC
STIPULATION AND ORDER FOR
SECOND EXTENSION OF TIME TO FILE
RESPONSE TO FIRST AMENDED
COMPLAINT PENDING SETTLEMENT
[E.D. Local Rule 144; Fed. R. Civ. P. 6]

21
22
23
24
25
26
27
28

STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

1

Pursuant to Eastern District Civil Local Rule 144 and Federal Rule of Civil

2

Procedure 6, Defendants San Joaquin County, Sheriff Steve Moore, and Danny

3

Swanson (collectively “Defendants”) and Plaintiff Jane Doe (“Plaintiff”), by and through

4

their attorneys of record, stipulate to an extension of time for all Defendants to move,

5

plead, or otherwise respond to Plaintiff’s First Amended Complaint (“FAC”), as follows:

6
7
8

1.

On June 9, 2019, Plaintiff filed her FAC, alleging various federal and state

law claims.
2.

The parties agreed to conduct a mediation; therefore, on June 13, 2019,

9

the parties filed a stipulation extending Defendants’ time to respond to Plaintiff’s FAC to

10

August 19, 2019, pending the mediation, which the Court so ordered on June 14, 2019.

11
12
13
14
15
16
17
18
19

3.

On August 5, 2019, all parties and their counsel attended the mediation.

At the mediation, they were able to reach a global settlement of the entire action subject
to certain specific conditions. If the conditions are satisfied, this entire action will be
dismissed with prejudice.
4.

The parties anticipate it will take approximately 60 days to finalize the

settlement documents and perform these conditions.
5.

The parties thus request that Defendants’ time to move, plead, or

otherwise respond to Plaintiff’s FAC be extended 90 days, through and including
November 18, 2019. There is no trial date and the Court has not yet issued a Rule 16
scheduling order.

20
21
22
23
24

Based on the foregoing, IT IS STIPULATED, by and between all parties through
their respective counsel of record, that:
(1) Defendants San Joaquin County and Sheriff Steve Moore’s deadline to move,
plead, or otherwise respond to the FAC be extended through and including
November 18, 2019.

25
26
27
28
2
STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING

1
2
3
4

(2) Defendant Danny Swanson’s deadline to move, plead, or otherwise respond
to the FAC be extended through and including November 18, 2019.
IT IS SO STIPULATED.
Dated: August 7, 2019

5

By: __/s/ Dana A. Suntag____ _________
DANA A. SUNTAG
Attorneys for Defendants
COUNTY OF SAN JOAQUIN and
SHERIFF STEVE MOORE

6
7
8

HERUM CRABTREE SUNTAG
A California Professional Corporation

Dated: August 7, 2019

BURKE, WILLIAMS, & SORENSEN, LLP

9
By: __/s/ Gregory B. Thomas__________
GREGORY B. THOMAS
Attorneys for Defendant
DANNY SWANSON

10
11
12

Dated: August 7, 2019

13

By: __/s/ Stanley Goff_______ ________
STANLEY GOFF, ESQ.
Attorneys for Plaintiff
JANE DOE

14
15
16
17
18
19
20

LAW OFFICES OF STANLEY GOFF

ORDER
IN CONSIDERATION of the parties’ Stipulation, and for good cause shown
therein, it is ORDERED that Defendants’ deadline to move, plead, or otherwise respond
to Plaintiff’s First Amended Complaint is extended from August 19, 2019 through and
including November 18, 2019.
Dated: August 7, 2019

21
22
Troy L. Nunley
United States District Judge

23
24
25
26
27
28
3

STIPULATION AND ORDER FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING