Government App Solutions, Inc. v. FBI, et al

Filing 50

ORDER signed by District Judge Troy L. Nunley on 9/9/2021 CONTINUING to 9/20/2021, that the deadline for the Federal Defendants to respond to the First Amended Complaint (ECF 6 ). (Reader, L)

Case 2:21-cv-00696-TLN-KJN Document 50 Filed 09/09/21 Page 1 of 2
1 PHILLIP A. TALBERT
Acting United States Attorney
2 PHILIP A. SCARBOROUGH (SBN 254934)
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: [phone]
Facsimile: [phone]
5 [e-mail]
6 Attorneys for the United States
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IN THE UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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GOVERNMENT APP SOLUTIONS, INC.,
Plaintiff,

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v.

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FEDERAL BUREAU OF INVESTIGATION,
et al.,

CASE NO. 2:21-CV-00696-TLN-KJN
STIPULATION AND ORDER TO CONTINUE
DEADLINE TO RESPOND TO COMPLAINT
JUDGE:

Hon. Troy L. Nunley

Defendants.

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Plaintiff Government App Solutions, Inc., and defendants the United States of America, sued

18 herein as the Federal Bureau of Investigation and the United States Attorney’s Office for the Eastern
19 District of California; Michael Anderson; Amy S. Hitchcock; Rebekah Bills; and Rachael LaChapelle
20 (together, the “Federal Defendants”) jointly stipulate and respectfully request that the Court continue the
21 deadline for the Federal Defendants to respond to the First Amended Complaint (“FAC”) (ECF 6) by
22 one week, to September 20, 2021. Good cause for the requested extension exists for the following
23 reasons.
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The deadline for the Federal Defendants to respond to the complaint currently is September 13,

25 2021. See ECF 21 at 3. Counsel for plaintiff and counsel for the Federal Defendants have been meeting
26 and conferring with the goal of narrowing the issues that must be resolved by the Court through a
27 motion to dismiss the claims against the Federal Defendants. As part of the meet and confer process,
28 counsel for plaintiff requires one additional week to conduct legal research. Accordingly, the parties
STIPULATION AND ORDER TO CONTINUE
DEADLINE TO RESPOND TO COMPLAINT

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Case 2:21-cv-00696-TLN-KJN Document 50 Filed 09/09/21 Page 2 of 2
1 jointly stipulate and request that the Court extend the deadline for the Federal Defendants to respond to
2 the FAC by one week, to September 20, 2021, so the parties may conclude the meet and confer process.
Respectfully submitted,

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4 Dated: September 8, 2021

PHILLIP A. TALBERT
Acting United States Attorney

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By: /s/ Philip A. Scarborough
PHILIP A. SCARBOROUGH
Assistant United States Attorney

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Attorneys for defendants the United States,
Rebekah Bills, Rachel LaChapelle, Michael
Anderson, and Amy S. Hitchcock

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10 Dated: September 8, 2021

CYRUS ZAL, A PROFESSIONAL
CORPORATION

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By: /s/ Cyrus Zal
CYRUS ZAL

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Attorney for plaintiff Government App
Solutions, Inc.

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ORDER
Good cause appearing, the stipulation of plaintiff Government App Solutions, Inc., and
defendants Rebekah Bills, Rachael LaChapelle, Michael Anderson, Amy S. Hitchcock, and the United
States, sued herein as the Federal Bureau of Investigation and the United States Attorney’s Office for the
Eastern District of California (together, the “Federal Defendants”), is hereby APPROVED. The
deadline for the Federal Defendants to respond to the First Amended Complaint (ECF 6) is continued to
September 20, 2021.
IT IS SO ORDERED.

Dated: September 9, 2021
Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER TO CONTINUE
DEADLINE TO RESPOND TO COMPLAINT

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