Loescher v. County of Plumas et al

Filing 38

STIPULATION and ORDER signed by Chief District Judge Kimberly J. Mueller on 11/13/2020 GRANTING Request for Extension of time. Defendants COUNTY OF PLUMAS and SHERIFF GREG HAGWOOD shall file a responsive pleading by no later than 11/25/2020. (Mena-Sanchez, L)

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1 2 3 4 5 LARRY L. BAUMBACH (State Bar No. 50086) LAW OFFICES OF LARRY L. BAUMBACH 2531 Forest Avenue, Suite 100 Chico, CA 95928 Telephone: 530-891-6222 Fax: 530-852-3969 Email: llblaw@sandpipernet.com Attorney for Plaintiff LYNNE LOESCHER 6 7 RIVERA HEWITT PAUL LLP 8 11341 Gold Express Drive, Suite 160 Gold River, California 95670 9 Tel: 916-922-1200 Fax: 916 922-1303 10 11 12 13 Shanan L. Hewitt, SBN 200168 SHewitt@rhplawyers.com Attorneys for Defendants COUNTY OF PLUMAS and SHERIFF GREG HAGWOOD 14 15 IN THE UNITED STATES DISTRICT COURT 16 IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA 17 18 LYNNE LOESCHER, 19 Plaintiff, 20 vs. 21 COUNTY OF PLUMAS, PLUMAS COUNTY SHERIFF GREG HAGWOOD, CALIFORNIA HIGHWAY PATROL OFFICER SARGENT KELLY SERIAL NUMBER 52, and DOES 1through 50, inclusive, 22 23 24 CASE NO: 2:19-CV-1984-KJM-KJN STIPULATION and ORDER FOR AN EXTENSION OF TIME TO FILE A RESPONSIVE PLEADING TO SECOND AMENDED COMPLAINT [E.D. Cal. L.R. 144(a)] 25 26 Defendants. 27 28 RIVERA HEWITT PAUL LLP 11341 Gold Express Drive, Suite 160 Gold River, CA 95670 (916) 922-1200 STIPULATION AND ORDER FOR AN EOT TO FILE RESPONSIVE PLEADING Case No. 2:18-cv-01020 MCE EFB 1 1 Plaintiff, by and through her counsel Larry L. Baumbach, Esq. of the Law Offices of 2 Larry L. Baumbach and Defendants County of Plumas and Sheriff Greg Hagwood, by and 3 through their counsel Shanan L. Hewitt, Esq. of the Law Offices of Rivera Hewitt Paul LLP, 4 hereby stipulate pursuant to Local Rule of Court 144(a) to an extension of time in order to permit 5 Defendants County of Plumas and Sheriffs Greg Hagwood to file a responsive pleading to 6 Plaintiff’s Second Amended Complaint (Doc. 35) filed on October 30, 2020. The parties stipulate 7 and have agreed to extend the responsive pleading deadline as follows: 8 (1) The undersigned defense counsel is currently working on additional matters which have 9 upcoming litigation deadlines including, but not limited to, an extensive motion for 10 summary judgment and a request to seal documents in Pervez v. Bacerra, et al., Case No: 11 2:18-cv-02793-KJM-KJN which is due by November 13, 2020, in addition to several 12 depositions in other cases during the week of November 2, 2020. 13 (2) In order to thoroughly review the Second Amended Complaint, research and evaluate 14 whether a motion to dismiss is warranted and allow sufficient time for the parties to meet 15 and confer prior to the filing of such a motion, Defendants County of Plumas and Sheriff 16 Hagwood respectfully request an extension of time to file a responsive pleading. 17 Plaintiff’s counsel has kindly agreed to stipulate to this request. 18 (3) The parties have agreed and hereby stipulate to extend the time for Defendants County of 19 Plumas and Sheriff Greg Hagwood to respond to the Second Amended Complaint (Doc. 20 35) from the original deadline of November 13, 2020 up to and including November 25, 21 2020. 22 IT IS SO STIPULATED. 23 24 Dated: November 6, 2020 RIVERA HEWITT PAUL LLP 25 _/s/ Shanan L. Hewitt________ SHANAN L. HEWITT Attorneys for Defendants COUNTY OF PLUMAS and SHERIFF GREG HAGWOOD 26 27 28 RIVERA HEWITT PAUL LLP 11341 Gold Express Drive, Suite 160 Gold River, CA 95670 (916) 922-1200 STIPULATION AND ORDER FOR AN EOT TO FILE RESPONSIVE PLEADING Case No. 2:18-cv-01020 MCE EFB 2 1 Dated: November 10, 2020 LAW OFFICES OF LARRY L. BAUMBACH 2 _/s/ Larry L. Baumbach________ LARRY L. BAUMBACH Attorney for Plaintiff LYNNE LOESCHER 3 4 5 ORDER 6 7 GOOD CAUSE having been shown, the foregoing stipulated request for an extension of 8 time for Defendants COUNTY OF PLUMAS and SHERIFF GREG HAGWOOD to file a 9 responsive pleading to Plaintiff’s Second Amended Complaint (Doc. 35) is HEREBY 10 GRANTED. Defendants shall file and serve their responsive pleading to Plaintiff’s Second 11 Amended Complaint no later than November 25, 2020. 12 IT IS SO ORDERED. 13 14 Dated: November 13, 2020 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RIVERA HEWITT PAUL LLP 11341 Gold Express Drive, Suite 160 Gold River, CA 95670 (916) 922-1200 STIPULATION AND ORDER FOR AN EOT TO FILE RESPONSIVE PLEADING Case No. 2:18-cv-01020 MCE EFB 3

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