Caldeira v. Emergy Inc.
Filing
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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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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
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION
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SERENA CALDEIRA, an individual,
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Plaintiff,
v.
EMERGY INC. doing business as MEATI
FOODS, and DOES 1 through 100, inclusive,
Defendant.
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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
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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
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and between Plaintiff Serena Caldeira (“Plaintiff”) and Defendant Emergy Inc. d/b/a Meati Foods
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(“Defendant”) (collectively the “Parties”), to extend Defendant’s deadline to respond to
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Plaintiff’s Complaint, as follows:
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WHEREAS, Plaintiff filed the instant Complaint on June 24, 2024;
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WHEREAS, Plaintiff served the Summons and Complaint on Defendant on July 9, 2024
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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
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to explore early resolution, Defendant requests additional time to respond to Plaintiff’s Complaint;
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WHEREAS, counsel for the Parties have met and conferred and agreed to extend
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Defendant’s deadline to respond to Plaintiff’s Complaint by 32 days from October 24, 2024 to
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November 25, 2024;
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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
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WHEREAS, this is the fourth request for extension.
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//
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///
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//
FAEGRE DRINKER BIDDLE &
REATH LLP
LOS ANGELES
and Defendant’s deadline to respond was July 30, 2024;
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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
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THEREFORE, IT IS HEREBY STIPULATED, pending the approval of this Court,
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that Defendant has an extension of time to respond to the Complaint to and including November
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25, 2024.
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Dated: October 23, 2024
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FAEGRE DRINKER BIDDLE & REATH LLP
By:
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/s/ Whitney A. Thompson
WHITNEY A. THOMPSON
Attorneys for Defendant
EMERGY INC. d/b/a MEATI FOODS
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Dated: October 23, 2024
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FRANK SIMS & STOLPER LLP
By:
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/s/ Jason M. Frank
JASON M. FRANK
SCOTT H. SIMS
ANDREW D. STOLPER
Attorneys for Plaintiff
SERENA CALDEIRA
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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
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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.
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Dated: October 23, 2024
/s/ Whitney Thompson
Whitney Thompson
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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
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ORDER
IT IS HEREBY ORDERED THAT:
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Pursuant to the Parties’ Fourth Joint Stipulation, Defendant’s deadline to respond to
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Plaintiff’s Complaint is extended to November 25, 2024. The Court will not consider any further
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requests for extension of time absent good cause.
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IT IS SO ORDERED.
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Dated: October 23, 2024
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/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
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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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