Caldeira v. Emergy Inc.

Filing 17

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 10/23/2024 EXTENDING the deadline to respond to the 1 Complaint to 11/25/2024. (Woodson, A)

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1 2 3 4 5 6 FAEGRE DRINKER BIDDLE & REATH LLP WHITNEY A. THOMPSON (SBN 336655) whitney.thompson@faegredrinker.com 1800 Century Park East, Suite 1500 Los Angeles, California 90067 Telephone: +1 310 203 4000 Facsimile: +1 310 229 1285 Attorneys for Defendant EMERGY INC. d/b/a MEATI FOODS 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION 10 11 SERENA CALDEIRA, an individual, 12 13 14 15 16 Plaintiff, v. EMERGY INC. doing business as MEATI FOODS, and DOES 1 through 100, inclusive, Defendant. 17 Case No. 2:24-cv-01775-DJC-JDP Hon. Daniel J. Calabretta Courtroom 10 FOURTH JOINT STIPULATION AND ORDER TO EXTEND DEFENDANT’S TIME TO RESPOND TO COMPLAINT Complaint Filed: Current Response Date: New Response Date: June 24, 2024 Oct. 24, 2024 Nov. 25, 2024 18 19 20 21 22 23 24 25 26 27 28 FAEGRE DRINKER BIDDLE & REATH LLP ATTORNEYS AT LAW LOS ANGELES FOURTH STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT CASE NO. 2:24-CV-01775-DJC-JDP 1 2 and between Plaintiff Serena Caldeira (“Plaintiff”) and Defendant Emergy Inc. d/b/a Meati Foods 3 (“Defendant”) (collectively the “Parties”), to extend Defendant’s deadline to respond to 4 Plaintiff’s Complaint, as follows: 5 WHEREAS, Plaintiff filed the instant Complaint on June 24, 2024; 6 WHEREAS, Plaintiff served the Summons and Complaint on Defendant on July 9, 2024 7 8 9 10 11 12 13 14 15 WHEREAS, on July 29, 2024, the Parties stipulated to extend the time for Defendant to respond to the Complaint by 28 days to August 27, 2024 (Dkt. No. 7); WHEREAS, on August 26, 2024, the Parties stipulated to extend the time for Defendant to respond to the Complaint by 30 days to September 26, 2024 (Dkt. No. 8); WHEREAS, on September 24, 2024, the Parties stipulated to extend the time for Defendant to respond to the Complaint by 28 days to October 24, 2024 (Dkt. No. 12); WHEREAS, on September 27, 2024, the Court ordered that Defendant’s deadline to respond to the Complaint is extended to October 24, 2024 (Dkt. No. 15); WHEREAS, to allow Defendant to further investigate Plaintiff’s claims and for the Parties 17 to explore early resolution, Defendant requests additional time to respond to Plaintiff’s Complaint; 18 WHEREAS, counsel for the Parties have met and conferred and agreed to extend 19 Defendant’s deadline to respond to Plaintiff’s Complaint by 32 days from October 24, 2024 to 20 November 25, 2024; 22 23 24 WHEREAS, this request is made in good faith and not for the purposes of delay, but for judicial and party efficiency; WHEREAS, the requested extension will not alter the date of any event or any deadline already fixed by Court order; and 25 WHEREAS, this is the fourth request for extension. 26 // 27 /// 28 // FAEGRE DRINKER BIDDLE & REATH LLP LOS ANGELES and Defendant’s deadline to respond was July 30, 2024; 16 21 ATTORNEYS AT LAW IT IS HEREBY STIPULATED AND AGREED, pursuant to Local Rules 143-144, by FOURTH STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT -2- CASE NO. 2:24-CV-01775-DJC-JDP 1 THEREFORE, IT IS HEREBY STIPULATED, pending the approval of this Court, 2 that Defendant has an extension of time to respond to the Complaint to and including November 3 25, 2024. 4 5 Dated: October 23, 2024 6 FAEGRE DRINKER BIDDLE & REATH LLP By: 7 8 /s/ Whitney A. Thompson WHITNEY A. THOMPSON Attorneys for Defendant EMERGY INC. d/b/a MEATI FOODS 9 10 Dated: October 23, 2024 11 FRANK SIMS & STOLPER LLP By: 12 13 /s/ Jason M. Frank JASON M. FRANK SCOTT H. SIMS ANDREW D. STOLPER Attorneys for Plaintiff SERENA CALDEIRA 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FAEGRE DRINKER BIDDLE & REATH LLP ATTORNEYS AT LAW LOS ANGELES FOURTH STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT -3- CASE NO. 2:24-CV-01775-DJC-JDP 1 2 3 ATTESTATION I attest that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the filing. 4 5 Dated: October 23, 2024 /s/ Whitney Thompson Whitney Thompson 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FAEGRE DRINKER BIDDLE & REATH LLP ATTORNEYS AT LAW LOS ANGELES FOURTH STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT -4- CASE NO. 2:24-CV-01775-DJC-JDP 1 2 ORDER IT IS HEREBY ORDERED THAT: 3 Pursuant to the Parties’ Fourth Joint Stipulation, Defendant’s deadline to respond to 4 Plaintiff’s Complaint is extended to November 25, 2024. The Court will not consider any further 5 requests for extension of time absent good cause. 6 7 IT IS SO ORDERED. 8 9 Dated: October 23, 2024 10 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FAEGRE DRINKER BIDDLE & REATH LLP ATTORNEYS AT LAW LOS ANGELES ORDER GRANTING FOURTH STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT -5- CASE NO. 2:24-CV-01775-DJC-JDP

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