(PC) Doe v. Johnson et al
Filing
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STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 1/24/2025 GRANTING 32 Stipulation. The deadline for Defendants Gonzalez, Macomber, and Montes to respond to 27 Second Amended Complaint is EXTENDED up to and including 2/28/2025. (Deputy Clerk HAH)
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ROB BONTA, State Bar No. 202668
Attorney General of California
ALICIA A. BOWER, State Bar No. 287799
Supervising Deputy Attorney General
ARTHUR B. MARK III, State Bar No. 220865
Deputy Attorney General
1300 I Street, Suite 125
P.O. Box 944255
Sacramento, CA 94244-2550
Telephone: (916) 210-7345
Fax: (916) 324-5205
E-mail: Arthur.Mark@doj.ca.gov
Attorneys for Defendants
J. Macomber, R. Montes and L. Gonzalez
IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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JANE DOE #1,
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v.
MARCUS JOHNSON, et al.,
2:24-cv-1542 DJC AC P
Plaintiff, STIPULATION TO EXTEND TIME FOR
DEFENDANTS GONZALEZ,
MACOMBER, AND MONTES TO
RESPOND TO PLAINTIFF’S SECOND
AMENDED COMPLAINT
[PROPOSED] ORDER
Defendants.
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Judge:
Honorable Allison Claire
Trial Date:
None set
Action Filed: May 31, 2024
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STIPULATION
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Pursuant to Federal Rule of Civil Procedure 6(b), the parties, by and through their attorneys
of record, stipulate as follows:
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Plaintiff Jane Doe #1 filed her operative Second Amended Complaint on November
21, 2024 (ECF No. 27).
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On December 6, 2024, the Court issued its screening order regarding the Second
Amended Complaint and ordered Defendants L. Gonzalez, J. Macomber, and R. Montes
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Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd.
Compl. (2:24-cv-1542 DJC AC)
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(Defendants)1 to respond to the Second Amended Complaint within 21 days of the filing of the
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order, making Defendants’ initial deadline December 27, 2024 (ECF No. 28).
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On December 26, 2024, the Court granted the parties’ stipulated request to extend the
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time for Defendants to respond to the Second Amended Complaint until January 24, 2025. (ECF
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No. 31).
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4.
Since that extension, the parties have met and conferred regarding the claims and
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allegations in Plaintiff’s Second Amended Complaint and grounds for a motion to dismiss by
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Defendants, including but not limited to, a challenge to Plaintiff’s standing to pursue injunctive
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relief and whether Plaintiff complied with the California Government Claims Act. Specifically,
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Defendants’ counsel prepared and sent a letter to Plaintiff’s counsel on January 17, 2025,
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outlining arguments for dismissal and the parties then conferred via video-conference on these
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grounds on January 22, 2025. In addition, the parties are currently considering whether to pursue
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early ADR, and Defendants have agreed to provide some documents under a protective order to
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Plaintiff so that the parties may more fully evaluate Plaintiff’s claims. Accordingly, additional
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time to respond to the operative complaint is warranted to allow this exchange of information,
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including the preparation and entry of a protective order; for additional discussion of the viability
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of Plaintiff’s claims against Defendants; and for the parties to more fully consider whether early
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ADR is appropriate for this matter.
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5.
In addition, Defendants’ counsel has been occupied with other matters. Mr. Mark
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was out of the office from December 30, 2024 to January 10, 2025. During Mr. Mark’s absence,
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Mr. Glantz was required to work on other pressing matters, including reviewing and responding
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to seven motions for remand in seven separate matters. And Mr. Glantz has been working to
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respond to an administrative subpoena in a matter involving the United States Department of
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Justice, which response is currently due January 24, 2025.
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6.
The parties have conferred and agree that additional time to respond to the Second
Amended Complaint until February 28, 2025, will allow the parties time to exchange documents,
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The undersigned counsel does not represent Defendant Johnson.
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Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd.
Compl. (2:24-cv-1542 DJC AC)
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conduct additional investigation concerning Plaintiff’s claims, meet and confer further regarding
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Plaintiff’s claims, and consider whether early ADR is appropriate for this matter.
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7.
Accordingly, the parties stipulate and respectfully request that Defendants L.
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Gonzalez, J. Macomber, and R. Montes shall have up to and including February 28, 2025 to
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respond to the Second Amended Complaint.
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IT IS SO STIPULATED.
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Dated: January 24, 2025
/s/ Jenny C. Huang
(as authorized January 24, 2025)
Jenny C. Huang
Attorney for Plaintiff, Jane Doe #1
Dated: January 24, 2025
ROB BONTA
Attorney General of California
ALICIA A. BOWER
Supervising Deputy Attorney General
ZACHARY GLANTZ
Deputy Attorney General
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/s/ Arthur B. Mark III
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ARTHUR B. MARK III
Deputy Attorney General
Attorneys for Defendants L. Gonzalez, J.
Macomber, and R. Montes
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SA2024303498
38734994.docx
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Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd.
Compl. (2:24-cv-1542 DJC AC)
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[PROPOSED] ORDER
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Good cause appearing, the parties’ stipulation is GRANTED. The deadline for Defendants
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Gonzalez, Macomber, and Montes to respond to Plaintiff’s Second Amended Complaint is hereby
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extended up to and including February 28, 2025.
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IT IS SO ORDERED.
DATED: January 24, 2025
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Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd.
Compl. (2:24-cv-1542 DJC AC)
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