Pollard v. Soloniuk Clinic et al

Filing 54

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr., on 2/1/24, ORDERING that Defendants should answer or otherwise respond to the Complaint in Intervention on or before 3/4/24. (Kastilahn, A)

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Malcolm Segal (SBN 075481)
Emily E. Doringer (SBN 208727)
SEGAL & ASSOCIATES, PC
500 Capitol Mall, Suite 600
Sacramento, CA 95814
Telephone: [phone]

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[e-mail]
[e-mail]

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Attorneys for Defendants
THEODORE WORKMAN, JR, and
SOLONIUK PAIN CLINIC, a Medical Corporation
Nick Jurkowitz (SBN 261283)
Elaine Sun (SBN 333985)
Fenton Law Group
1990 S Bundy, Suite 777
Los Angeles, CA 90025
Phone: [phone]
[e-mail]
[e-mail]

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Attorneys for Defendant
LEONARD SOLONIUK
Steven Tennyson (SBN 310429)
UNITED STATES ATTORNEY’S OFFICE
Eastern District of California
501 I Street, Suite 10-100
Sacramento, CA 95814
Phone: [phone]
[e-mail]

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Attorneys for Plaintiff
UNITED STATES OF AMERICA

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(Additional Attorneys in Signature Page)

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-1Stip. Extend Time for Response to Complaint in Intervention; Order

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNITED STATES OF AMERICA, ex rel.
EDWARD POLLARD,

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Plaintiff,
v.
THEODORE WORKMAN, JR;
LEONARD SOLONIUK; and
SOLONIUK PAIN CLINIC, a Medical
Corporation,

Case No: 2:19-cv-0325 MCE DB

STIPULATION TO EXTEND TIME FOR
DEFENDANTS TO RESPOND TO
COMPLAINT IN INTERVENTION;
ORDER

Defendants.

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IT IS HEREBY STIPULATED by and between the parties hereto through

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their respective counsel that Defendants THEODORE WORKMAN, JR,

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LEONARD SOLONIUK and SOLONIUK PAIN CLINIC, a Medical Corporation,

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may have additional time for filing of an answer or otherwise respond to the

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Complaint in Intervention. The Complaint in Intervention was filed on December 1,

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2023. A Summons issued December 6, 2023, with notice sent to the defendants

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the following day. Defendants filed waivers of service and the last day for

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defendants to answer or otherwise respond to plaintiff’s complaint is February 5,

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2024. The parties stipulate pursuant to Rule 6 of the Federal Rules of Civil

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Procedure and Local Rule 144 that Defendants shall have until March 4, 2024, to

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answer or otherwise respond to the Complaint in Intervention.

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Good cause exists for this extension due to professional and travel

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commitments of defense counsel and defendants, as well as additional defense

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counsel’s assignment to the matter, requiring additional time to prepare an initial

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pleading.
-2Stip. Extend Time for Response to Complaint in Intervention; Order

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This document is being electronically filed through the Court’s ECF System.

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In this regard, counsel for Defendants hereby attests that (1) the content of this

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document is acceptable to all persons required to sign the document; (2)

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Plaintiff’s counsel has concurred with the filing of this document; and (3) a record

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supporting this concurrence is available for inspection or production if so ordered.

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Dated: January 30, 2024.

SEGAL & ASSOCIATES, PC

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/s/ Emily E. Doringer_____________________
Malcolm Segal
Emily E. Doringer
Attorneys for Defendants
THEODORE WORKMAN, JR, and
SOLONIUK PAIN CLINIC, a Medical Corporation

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Dated: January 30, 2024.

FENTON LAW GROUP

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/s/ Nick Jurkowitz_____________________
Nick Jurkowitz
Elaine Sun
Attorneys for Defendant
LEONARD SOLONIUK

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Dated: January 30, 2024.

UNITED STATES ATTORNEY’S OFFICE

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/s/ Steven Tennyson____________________
Steven Tennyson
Attorneys for Plaintiff
UNITED STATES OF AMERICA

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-3Stip. Extend Time for Response to Complaint in Intervention; Order

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Dated: January 30, 2024.

HIRST LAW GROUP

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/s/ Michael A. Hirst_________________

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Michael A. Hirst (SBN 131034)
Marisela Bernal (SBN 329589)
HIRST LAW GROUP
200 B Street, Suite A
Davis, CA 95616
Phone: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiff
EDWARD POLLARD

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Dated: January 30, 2024.

JS ABRAMS LAW, PC

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/s/ Navid Kanani________________________
Navid Kanani (SBN 270797)
JS ABRAMS LAW, PC
20501 Ventura Blvd., Suite 165
Woodland Hills, CA 91364
Phone: [phone]
[e-mail]
Attorneys for Plaintiff
EDWARD POLLARD

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-4Stip. Extend Time for Response to Complaint in Intervention; Order

ORDER

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Pursuant to the parties’ stipulation, IT IS SO ORDERED. Defendants
should answer or otherwise respond to the Complaint in Intervention on or before
March 4, 2024.
IT IS SO ORDERED.
Dated: February 1, 2024

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-5Stip. Extend Time for Response to Complaint in Intervention; Order