(PC) Doe #2 v. Johnson et al

Filing 26

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 01/24/2025 EXTENDING the deadline for Defendants Gonzalez, Macomber, and Montes to respond to Plaintiff's 20 First Amended Complaint to 2/28/2025. (Deputy Clerk KS)

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1 2 3 4 5 6 7 8 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, L. Gonzalez and R. Montes IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 SACRAMENTO DIVISION 11 12 13 JANE DOE #2, 14 15 16 17 v. MARCUS JOHNSON, et al., 2:24-cv-1844 DJC AC P Plaintiff, STIPULATION TO EXTEND TIME FOR DEFENDANTS GONZALEZ, MACOMBER, AND MONTES TO RESPOND TO PLAINTIFF’S FIRST AMENDED COMPLAINT [PROPOSED] ORDER Defendants. 18 Judge: Hon. Allison Claire Trial Date: None set Action Filed: July 1, 2024 19 20 STIPULATION 21 22 23 24 25 26 27 28 Pursuant to Federal Rule of Civil Procedure 6(b), the parties, by and through their attorneys of record, stipulate as follows: 1. Plaintiff Jane Doe #2 filed her operative First Amended Complaint on November 21, 2024 (ECF No. 20). 2. 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 1 Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd. Compl. (2:24-CV-01844-DJC-AC (PC)) 1 (Defendants)1 to respond to the First Amended Complaint within 21 days of the filing of the 2 order, making Defendants’ initial deadline December 27, 2024 (ECF No. 21). 3 3. On December 26, 2024, the Court granted the parties’ stipulated request to extend the 4 time for Defendants to respond to the Second Amended Complaint until January 24, 2025. (ECF 5 No. 24). 6 4. Since that extension, the parties have met and conferred regarding the claims and 7 allegations in Plaintiff’s First Amended Complaint and grounds for a motion to dismiss by 8 Defendants, including but not limited to, a challenge to Plaintiff’s standing to pursue injunctive 9 relief and whether Plaintiff complied with the California Government Claims Act. Specifically, 10 Defendants’ counsel prepared and sent a letter to Plaintiff’s counsel on January 17, 2025, 11 outlining arguments for dismissal and the parties then conferred via video-conference on these 12 grounds on January 22, 2025. In addition, the parties are currently considering whether to pursue 13 early ADR, and Defendants have agreed to provide some documents under a protective order to 14 Plaintiff so that the parties may more fully evaluate Plaintiff’s claims. Accordingly, additional 15 time to respond to the operative complaint is warranted to allow this exchange of information, 16 including the preparation and entry of a protective order; for additional discussion of the viability 17 of Plaintiff’s claims against Defendants; and for the parties to more fully consider whether early 18 ADR is appropriate for this matter. 19 5. In addition, Defendants’ counsel has been occupied with other matters. Mr. Mark 20 was out of the office from December 30, 2024 to January 10, 2025. During Mr. Mark’s absence, 21 Mr. Glantz was required to work on other pressing matters, including reviewing and responding 22 to seven motions for remand in seven separate matters. And Mr. Glantz has been working to 23 respond to an administrative subpoena in a matter involving the United States Department of 24 Justice, which response is currently due January 24, 2025. 25 26 6. The parties have conferred and agree that additional time to respond to the First Amended Complaint until February 28, 2025, will allow the parties time to exchange documents, 27 28 1 The undersigned counsel does not represent Defendant Johnson. 2 Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd. Compl. (2:24-CV-01844-DJC-AC (PC)) 1 conduct additional investigation concerning Plaintiff’s claims, meet and confer further regarding 2 Plaintiff’s claims, and consider whether early ADR is appropriate for this matter. 3 7. Accordingly, the parties stipulate and respectfully request that Defendants L. 4 Gonzalez, J. Macomber, and R. Montes shall have up to and including February 28, 2025 to 5 respond to the First Amended Complaint. 6 IT IS SO STIPULATED. 7 8 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 9 10 11 12 13 14 15 /s/ Arthur B. Mark III 16 ARTHUR B. MARK III Deputy Attorney General Attorneys for Defendants L. Gonzalez, J. Macomber, and R. Montes 17 18 19 SA2024303521 38736162.docx 20 21 22 23 24 25 26 27 28 3 Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd. Compl. (2:24-CV-01844-DJC-AC (PC)) 1 2 [PROPOSED] ORDER Good cause appearing, the parties’ stipulation is GRANTED. The deadline for Defendants 3 Gonzalez, Macomber, and Montes to respond to Plaintiff’s First Amended Complaint is hereby 4 extended up to and including February 28, 2025. 5 6 IT IS SO ORDERED. DATED: January 24, 2025 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 Stipulation to Extend Time for Defendants Gonzalez, Macomber and Montes to Respond to Pl’s Second Amnd. Compl. (2:24-CV-01844-DJC-AC (PC))

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