Seijas v. The Jackson Laboratory, et al.,

Filing 16

STIPULATION and ORDER signed by District Judge Daniel J. Calabretta on 1/27/2025 EXTENDING the deadline for defendant The Jackson Laboratory's to respond to the #1 Complaint to 2/10/25. Plaintiff shall file an Amended Complaint by 2/10/25, and all parties shall file a joint rule report by 2/28/25. (Deputy Clerk AMW)

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1 2 3 4 5 6 7 8 9 10 11 SEYFARTH SHAW LLP Justin T. Curley (SBN 233287) jcurley@seyfarth.com 560 Mission Street, 31st Floor San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 SEYFARTH SHAW LLP Jeffrey A. Nordlander (SBN 308929) jnordlander@seyfarth.com 400 Capitol Mall, Suite 2350 Sacramento, California 95814-4428 Telephone: (916) 448-0159 Facsimile: (916) 558-4839 Attorneys for Defendant THE JACKSON LABORATORY dba THE JACKSON LABORATORY, WEST 16 LAWYERS For JUSTICE, PC Arby Aiwazian (SBN 269827) aa@calljustice.com Arman Marukyan (SBN 327150) arman@calljustice.com Dominic Scarangella (SBN 347695) d.scarangella@calljustice.com 450 North Brand Boulevard, Suite 900 Glendale, California 91203 Telephone: (818) 265-1020 Facsimile: (818) 265-1021 17 Attorneys for Plaintiff EMMALIE SEIJAS 12 13 14 15 18 UNITED STATES DISTRICT COURT 19 EASTERN DISTRICT OF CALIFORNIA 20 21 22 EMMALIE SEIJAS, individually, and on behalf of other members of the general public similarly situated and on behalf of other aggrieved employees pursuant to the California Private Attorneys General Act; 23 24 25 26 27 28 Plaintiff, v. THE JACKSON LABORATORY, an unknown business entity; THE JACKSON LABORATORY, WEST, a Maine corporation; and DOES 1 through 100, inclusive, Defendants. Case No. 2:24-cv-03423-DJC-AC HON. DANIEL J. CALABRETTA JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT THE JACKSON LABORATORY dba THE JACKSON LABORATORY, WEST TO FILE RESPONSIVE PLEADING AND FOR EXTENSION OF TIME FOR PARTIES TO FILE JOINT RULE 26(f) REPORT; ORDER Complaint filed: October 10, 2024 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING 1 Plaintiff Emmalie Seijas and Defendant The Jackson Laboratory dba The Jackson Laboratory, 2 West, by their counsel and pursuant to Federal Rule of Civil Procedure 6(b), hereby stipulate to 3 extending the time, by twenty-one (21) days, through and including January 27, 2025, for Defendant to 4 file its responsive pleading to Plaintiff’s Complaint. 5 6 WHEREAS, Plaintiff filed this action in Sacramento County Superior Court on October 18, 2024, 7 8 WHEREAS, Defendant removed Plaintiff’s Complaint to this Court pursuant to the Class Action Fairness Act of 2005 on December 9, 2024, 9 WHEREAS, Defendant’s responsive pleading deadline was initially December 16, 2024, which 10 the Parties stipulated to extend by 21 days, until January 6, 2025, while the Parties met and conferred 11 regarding Plaintiff’s Complaint, 12 13 WHEREAS, pursuant to pursuant to Local Rule 144(a), this stipulation was automatically effective upon filing of this stipulation without further action by the Court, 14 WHEREAS, to address Defendant’s contention that Plaintiff’s Complaint does not comply with 15 the pleading standards set forth in Federal Rule of Civil Procedure, Rule 8, Plaintiff has agreed to file an 16 Amended Complaint, 17 WHEREAS, on January 3, 2025, the Parties filed a Joint Stipulation for Extension of Time For 18 Defendant to File a Responsive Pleading to extend Defendant’s responsive pleading deadline to January 19 27, 2025 which was signed into order on January 7, 2025, 20 21 WHEREAS, Plaintiff is preparing an Amended Complaint, but will be unable to file the Amended Complaint before Defendant’s responsive pleading deadline on January 27, 2025, 22 WHEREAS, so that Defendant is not unnecessarily required to respond to Plaintiff’s initial 23 Complaint, by motion to dismiss or otherwise, pending Plaintiff’s filing her Amended Complaint, the 24 Parties hereby stipulate to extend Defendant’s responsive pleading deadline by 14 days, or until 25 February 10, 2025, 26 WHEREAS, the Parties current deadline to file their Joint Rule 26(f) Report is February 7, 2025, 27 /// 28 /// 1 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING 1 WHEREAS, the so that the Parties may have adequate time to finalize the pleadings prior to 2 submitting their Joint Rule 26(f) Report, the Parties hereby stipulate to extend the Parties’ deadline to 3 file their Joint Rule 26(f) Report by 21 days, or until February 28, 2025. 4 IT IS SO STIPULATED. 5 6 DATED: January 27, 2025 7 Respectfully submitted, SEYFARTH SHAW LLP 8 9 By: /s/ Jeffrey A. Nordlander Justin T. Curley Jeffrey A. Nordlander Attorneys for Defendant THE JACKSON LABORATORY dba THE JACKSON LABORATORY, WEST 10 11 12 13 14 15 DATED: January 27, 2025 Respectfully submitted, LAWYERS FOR JUSTICE, PC 16 17 18 19 By: /s/ Dominic Scarangella Arman Marukyan Dominic Scarangella Attorneys for Plaintiff EMMALIE SEIJAS 20 21 22 23 24 25 26 27 28 2 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING 1 2 3 Based on the Parties’ Joint Stipulation, and good cause appearing therefor, the Court GRANTS the Parties’ Joint Stipulation and orders as follows: 1. 4 Defendant The Jackson Laboratory’s deadline to respond to Plaintiff’s Complaint is hereby extended to February 10, 2025. 5 2. Plaintiff shall file her Amended Complaint on or before February 10, 2025. 6 3. The Parties shall file their Joint Rule 26(f) Report on or before February 28, 2025. 7 IT IS ORDERED. 8 9 10 Dated: January 27, 2025 /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 3 JOINT STIPULATION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADING; ORDER

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