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FILED , RECEIVED
Jerome Anthony Clay, Jr., Esq.,SBN 327175 SUPERIOR COURT-STOCKTON Oy gop aaratiay
LAW OFFICES OF JEROME A. CLAY
5250 Claremont Avenue, Suite 221 21 ct | 2, PH 1: 06
Stockton, California 95207 is
Telephone: (209) 603-9852 are * in
Facsimile: (510) 280-2841
E-mail: IJclay7@claylaw.net
~ .
Attorneys for Plaintiff
JEANINE D. DAVIS
ALDEN J. PARKER, SBN 196808
E-Mail: aparker@fisherphillips.com
CHRISTOPHER §. ALVAREZ, SBN 294795
E-Mail: calvarez@fisherphillips. com
ROBERT A. SARKISIAN, SBN 327364
E-Mail: rsatkisian@fisherphillips. com
FISHER & PHILLIPS LLP
621 Capitol Mall, Suite 1400
Sacramento, California 95814
Telephone: (916) 210-0400
Facsimile: (916) 210-0401
Attorneys for Defendant
MICHAEL TEMERIN dba STOCKTON TOWNHOUSE
APARTMENTS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN JOAQUIN
JEANINE D. DAVIS, CASE NO.: STK-CV-UOE-2021-0003224
[Unlimited Jurisdiction]
Plaintiff(s),
[Assigned for all purposes to the
v. Honorable Barbara Kronlund, Dept. 10D]
MICHAEL TEMERIN DBA STOCKTON JOINT STIPULATION FOR EXTENSION OF
TOWNHOUSE APARTMENTS; ALIS TIME FOR DEFENDANT TO FILE
VALENCIA; and DOES 1 through 50, RESPONSIVE PLEADING; {REGRGSED]
Inclusive, ORDER
Defendant(s).
Complaint Filed: April 13, 2021
First Amended Complaint: August 22, 2021
Trial Date: None Set
1
JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER
FP 41931456.1IT IS HEREBY STIPULATED by and between counsel for Plaintiff JEANINE D. DAVIS
(“Plaintiff”) and Defendant MICHAEL TEMERIN DBA STOCKTON TOWNHOUSE APARTMENTS
(“Defendant”), as follows:
WHEREAS, Plaintiff filed the original Complaint in this matter on April 13, 2021;
WHEREAS, Defendant met and conferred with Plaintiff's counsel regarding defects in the
Complaint. In response, Plaintiff filed and served a First Amended Complaint on August 23, 2021;
WHEREAS, Defendant met and conferred with Plaintiff's counsel regarding further defects in
the First Amended Complaint, and Plaintiff has indicated that she plans to file a Second Amended
Complaint in which, among other things, Defendant Alis Valencia will be dismissed.
WHEREAS, to conserve the Parties’ and judicial resources, and to give Plaintiff adequate time
to prepare and file her Second Amended Complaint, the Parties agree to extend Defendant’s deadline to
file a responsive pleading from October 8, 2021, through October 22, 2021.
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JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER
FP 41931456.1ay A WwW Bw wv
IT IS HEREBY STIPULATED AND PROPOSED BY THE PARTIES HERETO AS
FOLLOWS:
Defendant shall have until October 22, 2021, to file their responsive pleadings to Plaintiff's
Complaint.
IT IS SO STIPULATED.
DATE: October_@_, 2021 .W OFFICES OF JEROME A. CLAY
By: A
JEROME)A. CLAY ¥
Attorneys for Plaintiff
JEANINE D. DAVIS
DATE: October_8__, 2021 FISHER & PHILLIPS LLP
By: SEE <5
ALDEN J: PARKER
CHRISTOPHER S. ALVAREZ
ROBERT A. SARKISIAN
Attorneys for Defendant
MICHAEL TEMERIN dba STOCKTON
TOWNHOUSE APARTMENTS
3
JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER
FP 41931456.1wo oN A Uw fF WN
bow NR NY NY Fe Be Be ese ee ee Se
BNRR RE BEB F F&F CM ADA FW NH |=
The Court, having considered the Parties’ Stipulation, and good cause appearing, hereby orders
as follows:
The Parties’ Joint Stipulation to Extend Defendant’s Deadline to File a Responsive Pleading to
Plaintiff's Complaint is Granted. Defendant must file and serve a responsible pleading by October 22,
2021.
IT IS SO ORDERED.
patep: te Leo 22>] By:
"HON. BARBARA KRONLUND
4
JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER
FP 41931456.1 ‘PROOF OF SERVICE
(CCP § 1013(a) and 2015.5)
I, the undersigned, am at least 18 years old and not a party to this action. I am employed in the
County of Sacramento with the law offices of Fisher & Phillips LLP and its business address is 621
Capitol Mall, Suite 1400, Sacramento, California 95814.
On October 8, 2021, I served the foregoing document(s) JOINT STIPULATION FOR
EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING;
[PROPOSED] ORDER on the person(s) listed below as follows:
Jerome Anthony Clay, Jr., Esq. Attorneys for Plaintiff
LAW OFFICES OF JEROME A. CLAY Jeanine D. Davis
11 5250 Claremont Avenue, Suite 221
Stockton, CA 95207 E: Jelay7@claylaw.net
o [by MAIL] - I enclosed the document(s) in a sealed envelope or package addressed to the
person(s) whose address(es) are listed above and placed the envelope for collection and mailing,
following our ordinary business practices. I am readily familiar with this firm’s practice for
collecting and processing correspondence for mailing. On the same day that correspondence is
placed for collection and mailing, it is deposited in the ordinary course of business with the
United States Postal Service in Sacramento, California, in a scaled envelope with postage fully
prepaid.
O [by FAX] - Based on an agreement of the parties to accept scrvice by fax transmission, I faxed
the document(s) to the person(s) at fax number(s) listed above from fax number (916) 210-0401.
The machine printed a record of the transmission, and no error was reported by the machine.
oO [by OVERNIGHT DELIVERY] - I enclosed the document(s) in an envelope or package
provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed
above. I placed the envelope or package for collection and overnight delivery at an office or a
regularly utilized drop box of the overnight carrier.
a [by ELECTRONIC SERVICE] - Based on a court order or an agreement of the parties to accept
service by electronic transmission, I electronically served the document(s) to the person(s) at the
electronic service address(es) listed above.
o [by PERSONAL SERVICE] - | delivered the document(s) to the person(s) at the address(es)
listed above by (1) (a) personal delivery, or (b) by leaving the documents in an envelope/package
with an individual in charge of the office, or (c) by leaving them in a conspicuous place in the
office between the hours of 9:00 a.m. and 6:00 p.m., or (2) by messenger ~ a copy of the
Messenger Declaration is attached.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct.
Executed October 8, 2021, at Sacramento, California.
Alicia P. Malerbi By:
Print Name Signature
PROOF OF SERVICE
FP 41931456.1
Preview
0 wo YN HW RF WHY bow NY YP NY MN NN SB se Ee ee Se ee So 2 Aa A ke OW Ne Fe oS oO we NH DH BF Bw YH KF OS 4 FILED , RECEIVED Jerome Anthony Clay, Jr., Esq.,SBN 327175 SUPERIOR COURT-STOCKTON Oy gop aaratiay LAW OFFICES OF JEROME A. CLAY 5250 Claremont Avenue, Suite 221 21 ct | 2, PH 1: 06 Stockton, California 95207 is Telephone: (209) 603-9852 are * in Facsimile: (510) 280-2841 E-mail: IJclay7@claylaw.net ~ . Attorneys for Plaintiff JEANINE D. DAVIS ALDEN J. PARKER, SBN 196808 E-Mail: aparker@fisherphillips.com CHRISTOPHER §. ALVAREZ, SBN 294795 E-Mail: calvarez@fisherphillips. com ROBERT A. SARKISIAN, SBN 327364 E-Mail: rsatkisian@fisherphillips. com FISHER & PHILLIPS LLP 621 Capitol Mall, Suite 1400 Sacramento, California 95814 Telephone: (916) 210-0400 Facsimile: (916) 210-0401 Attorneys for Defendant MICHAEL TEMERIN dba STOCKTON TOWNHOUSE APARTMENTS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN JOAQUIN JEANINE D. DAVIS, CASE NO.: STK-CV-UOE-2021-0003224 [Unlimited Jurisdiction] Plaintiff(s), [Assigned for all purposes to the v. Honorable Barbara Kronlund, Dept. 10D] MICHAEL TEMERIN DBA STOCKTON JOINT STIPULATION FOR EXTENSION OF TOWNHOUSE APARTMENTS; ALIS TIME FOR DEFENDANT TO FILE VALENCIA; and DOES 1 through 50, RESPONSIVE PLEADING; {REGRGSED] Inclusive, ORDER Defendant(s). Complaint Filed: April 13, 2021 First Amended Complaint: August 22, 2021 Trial Date: None Set 1 JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER FP 41931456.1IT IS HEREBY STIPULATED by and between counsel for Plaintiff JEANINE D. DAVIS (“Plaintiff”) and Defendant MICHAEL TEMERIN DBA STOCKTON TOWNHOUSE APARTMENTS (“Defendant”), as follows: WHEREAS, Plaintiff filed the original Complaint in this matter on April 13, 2021; WHEREAS, Defendant met and conferred with Plaintiff's counsel regarding defects in the Complaint. In response, Plaintiff filed and served a First Amended Complaint on August 23, 2021; WHEREAS, Defendant met and conferred with Plaintiff's counsel regarding further defects in the First Amended Complaint, and Plaintiff has indicated that she plans to file a Second Amended Complaint in which, among other things, Defendant Alis Valencia will be dismissed. WHEREAS, to conserve the Parties’ and judicial resources, and to give Plaintiff adequate time to prepare and file her Second Amended Complaint, the Parties agree to extend Defendant’s deadline to file a responsive pleading from October 8, 2021, through October 22, 2021. Mt Mt Mt Mf - Mt dif i dit it Mt ut Mt Mt Mt dif it 2 JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER FP 41931456.1ay A WwW Bw wv IT IS HEREBY STIPULATED AND PROPOSED BY THE PARTIES HERETO AS FOLLOWS: Defendant shall have until October 22, 2021, to file their responsive pleadings to Plaintiff's Complaint. IT IS SO STIPULATED. DATE: October_@_, 2021 .W OFFICES OF JEROME A. CLAY By: A JEROME)A. CLAY ¥ Attorneys for Plaintiff JEANINE D. DAVIS DATE: October_8__, 2021 FISHER & PHILLIPS LLP By: SEE <5 ALDEN J: PARKER CHRISTOPHER S. ALVAREZ ROBERT A. SARKISIAN Attorneys for Defendant MICHAEL TEMERIN dba STOCKTON TOWNHOUSE APARTMENTS 3 JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER FP 41931456.1wo oN A Uw fF WN bow NR NY NY Fe Be Be ese ee ee Se BNRR RE BEB F F&F CM ADA FW NH |= The Court, having considered the Parties’ Stipulation, and good cause appearing, hereby orders as follows: The Parties’ Joint Stipulation to Extend Defendant’s Deadline to File a Responsive Pleading to Plaintiff's Complaint is Granted. Defendant must file and serve a responsible pleading by October 22, 2021. IT IS SO ORDERED. patep: te Leo 22>] By: "HON. BARBARA KRONLUND 4 JOINT STIPULATION FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER FP 41931456.1 ‘PROOF OF SERVICE (CCP § 1013(a) and 2015.5) I, the undersigned, am at least 18 years old and not a party to this action. I am employed in the County of Sacramento with the law offices of Fisher & Phillips LLP and its business address is 621 Capitol Mall, Suite 1400, Sacramento, California 95814. On October 8, 2021, I served the foregoing document(s) JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSIVE PLEADING; [PROPOSED] ORDER on the person(s) listed below as follows: Jerome Anthony Clay, Jr., Esq. Attorneys for Plaintiff LAW OFFICES OF JEROME A. CLAY Jeanine D. Davis 11 5250 Claremont Avenue, Suite 221 Stockton, CA 95207 E: Jelay7@claylaw.net o [by MAIL] - I enclosed the document(s) in a sealed envelope or package addressed to the person(s) whose address(es) are listed above and placed the envelope for collection and mailing, following our ordinary business practices. I am readily familiar with this firm’s practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service in Sacramento, California, in a scaled envelope with postage fully prepaid. O [by FAX] - Based on an agreement of the parties to accept scrvice by fax transmission, I faxed the document(s) to the person(s) at fax number(s) listed above from fax number (916) 210-0401. The machine printed a record of the transmission, and no error was reported by the machine. oO [by OVERNIGHT DELIVERY] - I enclosed the document(s) in an envelope or package provided by an overnight delivery carrier and addressed to the person(s) at the address(es) listed above. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight carrier. a [by ELECTRONIC SERVICE] - Based on a court order or an agreement of the parties to accept service by electronic transmission, I electronically served the document(s) to the person(s) at the electronic service address(es) listed above. o [by PERSONAL SERVICE] - | delivered the document(s) to the person(s) at the address(es) listed above by (1) (a) personal delivery, or (b) by leaving the documents in an envelope/package with an individual in charge of the office, or (c) by leaving them in a conspicuous place in the office between the hours of 9:00 a.m. and 6:00 p.m., or (2) by messenger ~ a copy of the Messenger Declaration is attached. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed October 8, 2021, at Sacramento, California. Alicia P. Malerbi By: Print Name Signature PROOF OF SERVICE FP 41931456.1