Decker v. County of Sacramento, et al

Filing 14

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 2/2/2024 DIRECTING defendants to respond to the #1 First Amended Complaint by 3/7/2024. (Woodson, A)

1
2
3
4
5
6
7
8

A PROFESSIONAL CORPORATION
William E. Camy, SBN 291397
Alison J. Southard, SBN 335716
2180 Harvard Street, Suite 500
Sacramento, CA 95815
TEL: [phone]
FAX: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
CITY OF RANCHO CORDOVA
Exempt from filing fee pursuant to Government Code section 6103

9
UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

BRIAN R. DECKER, an Individual,

CASE NO.: 2:24-cv-00021-DJC-AC

Plaintiff,

STIPULATION AND ORDER FOR EXTENSION
OF TIME FOR DEFENDANTS COUNTY OF
SACRAMENTO, SCOTT R. JONES,
SACRAMENTO MUNICIPAL UTILITY
DISTRICT, ROBERT DUGGAN, CITY OF
RANCHO CORDOVA, BRANDON M. LUKE,
GEORGE PARSONS, AND JEFF COUCH TO
RESPOND TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

vs.
COUNTY OF SACRAMENTO, a Municipal
Corporation;
SACRAMENTO
COUNTY
SHERIFF'S OFFICE, SCOTT R. JONES, in his
official capacity as Sacramento County Sheriff;
SACRAMENTO
MUNICIPAL
UTILITY
DISTRICT, a Municipal Utility District;
ROBERT DUGGAN, in his official capacity as an
employee of SMUD; CITY OF RANCHO
CORDOVA, a Municipal Corporation; CITY OF
RANCHO
CORDOVA
POLICE
DEPARTMENT, BRANDON M. LUKE in his
official capacity as Chief of Police, for the Rancho
Cordova
Police
Department;
GEORGE
PARSONS, in his official capacity as a
Sacramento County Sheriff's Deputy and/or a
Rancho Cordova Police Officer; JEFF COUCH,
in his official capacity as a Sacramento County
Sheriff's Deputy and/or a Rancho Cordova Police
Sergeant; and DOES 1 TO 50, inclusive.
Defendants.

Complaint filed: 11/04/2021

/

26
27
28

4876-6093-1146, v. 1
1
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS COUNTY OF SACRAMENTO, SCOTT
R. JONES, SACRAMENTO MUNICIPAL UTILITY DISTRICT, ROBERT DUGGAN, CITY OF RANCHO CORDOVA,
BRANDON M. LUKE, GEORGE PARSONS, AND JEFF COUCH TO RESPOND TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

1

WHEREAS, Plaintiff BRIAN R. DECKER (“Plaintiff’), Defendants CITY OF RANCHO

2

CORDOVA, COUNTY OF SACRAMENTO, SCOTT R. JONES, SACRAMENTO MUNICIPAL

3

UTILITY DISTRICT, ROBERT DUGGAN, CITY OF RANCHO CORDOVA, BRANDON M. LUKE,

4

GEORGE PARSONS, AND JEFF COUCH (“Defendants”) (Plaintiff and Defendants will be collectively

5

referred to as “Parties”) have been meeting and conferring regarding Defendants’ responsive pleading in

6

this matter, including a potential Motion to Dismiss.

7

WHEREAS, Counsel for Defendants CITY OF RANCHO CORDOVA, BRANDON M. LUKE,

8

GEORGE PARSONS, AND JEFF COUCH (collectively, “City Defendants”) provided Plaintiff’s counsel

9

with authority supporting its anticipated Motion to Dismiss.

10
11

WHEREAS, Plaintiff’s counsel indicated he would review the authorities described above and
possibly amend the First Amended Complaint (“FAC”) after reviewing the authorities.

12
13

WHEREAS, Plaintiff’s counsel is currently ill and likely would not be able to amend the FAC
prior to the current responsive pleading deadline, February 8, 2024.

14
15

WHEREAS, any responsive pleading filed by any of the Defendants in this matter may be rendered
moot if Plaintiff amends his FAC.

16

THEREFORE, IT IS HEREBY STIPULATED by and between the Parties, by and through their

17

respective undersigned counsel, that the time for Defendants herein to respond to the FAC shall be

18

extended up to and including March 7, 2024.

19
20

IT IS SO STIPULATED.

21
22

Dated: 2/2/2024

GORMAN LAW OFFICE

23
24

By _/s/ A. Alexander Gorman
A. Alexander Gorman
Attorney for Plaintiff BRIAN R. DECKER

25
26
27
28

///
///
4876-6093-1146, v. 1
2
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS COUNTY OF SACRAMENTO, SCOTT
R. JONES, SACRAMENTO MUNICIPAL UTILITY DISTRICT, ROBERT DUGGAN, CITY OF RANCHO CORDOVA,
BRANDON M. LUKE, GEORGE PARSONS, AND JEFF COUCH TO RESPOND TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

1

Dated: 2/2/2024

2
3

PORTER SCOTT
A PROFESSIONAL CORPORATION
By:

4
5
6
7
8
9

Dated: 2/2/2024

/s/ Alison J. Southard
William E. Camy
Alison J. Southard
Attorneys for Defendant
CITY OF RANCHO
CORDOVA

RIVERA HEWITT PAUL LLP

10
11

By:

12
13
14
15

Dated: 2/2/2024

/s/ Jonathan B. Paul
Jonathan B. Paul
Attorney for Defendant COUNTY OF
SACRAMENTO

LEWIS BRISBOIS BISGAARD &
SMITH LLP

16
17
18
19
20
21

By:

/s/ Jeffrey Schultz
Jeffrey Schultz
John Poulos
Attorneys for Defendant SACRAMENTO
MUNICIPAL UTILITY DISTRICT and
ROBERT DUGGAN

22
23
24
25
26
27
28

4876-6093-1146, v. 1
3
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS COUNTY OF SACRAMENTO, SCOTT
R. JONES, SACRAMENTO MUNICIPAL UTILITY DISTRICT, ROBERT DUGGAN, CITY OF RANCHO CORDOVA,
BRANDON M. LUKE, GEORGE PARSONS, AND JEFF COUCH TO RESPOND TO PLAINTIFF’S FIRST AMENDED
COMPLAINT

ORDER

1
2
3
4
5
6
7

Having reviewed the STIPULATION among the Parties and finding good cause therefore, it is
hereby ordered that:
The deadline for Defendants CITY OF RANCHO CORDOVA, COUNTY OF SACRAMENTO,
SCOTT R. JONES, SACRAMENTO MUNICIPAL UTILITY DISTRICT, ROBERT
DUGGAN, CITY OF RANCHO CORDOVA, BRANDON M. LUKE, GEORGE PARSONS,
AND JEFF COUCH shall be extended up to and including March 7, 2024.

8
9
10
11
12

IT IS SO ORDERED.

Dated: February 2, 2024

/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

4876-6093-1146, v. 1
4
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS COUNTY OF SACRAMENTO, SCOTT
R. JONES, SACRAMENTO MUNICIPAL UTILITY DISTRICT, ROBERT DUGGAN, CITY OF RANCHO CORDOVA,
BRANDON M. LUKE, GEORGE PARSONS, AND JEFF COUCH TO RESPOND TO PLAINTIFF’S FIRST AMENDED
COMPLAINT