Her v. County of Sacramento et al

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ORDER RE JOINT STIPULATION TO CONTINUE RESPONSIVE PLEADINGS DEADLINES
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A PROFESSIONAL CORPORATION
Derek J. Haynes, SBN 264621
dhaynes@porterscott.com
Steven E. Weiss, SBN 347790
sweiss@porterscott.com
2180 Harvard Street, Suite 500
Sacramento, California 95815
TEL: 916.929.1481
FAX: 916.927.3706
Attorneys for Defendant
COUNTY OF SACRAMENTO (erroneously sued as “COUNTY OF SACRAMENTO; SACRAMENTO COUNTY
SHERIFF’S DEPARTMENT”)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
JOHNNY HER,
Plaintiffs,
v.
COUNTY OF SACRAMENTO;
SACRAMENTO COUNTY SHERIFF’S
DEPARTMENT, a subsidiary of County of
Sacramento; TRACEY JACOBS; and DOES
1 through 50, inclusive,
Defendants. /
Case No.: 2:25−cv−2915−JDP
ORDER RE JOINT STIPULATION TO
CONTINUE RESPONSIVE PLEADINGS
DEADLINES
Defendant County of Sacramento (erroneously sued as Sacramento County Sheriff’s Department)
(hereinafter “the County”) was served with the Complaint from Plaintiff Johnny Her (hereinafter
“Plaintiff”) on September 8, 2025. Defendant Tracey Jacobs (hereinafter “Jacobs”) was served with the
Complaint from Plaintiff on September 8, 2025. The County, with the consent of Jacobs (collectively
hereinafter “Defendants”), filed a Notice of Removal on October 8, 2025.
Defendants’ responsive pleadings are currently due on December 10, 2025.
The Parties have been engaged in efforts to meet and confer on the Complaint and Defendants’
issues therewith. Plaintiff has indicated he is willing to file an amended complaint, but needs additional
time in which to do so.
Therefore, the Parties agree that moving the deadline for Defendants to respond to Plaintiff’s

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ORDER RE JOINT STIPULATION TO CONTINUE RESPONSIVE PLEADINGS DEADLINES
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Complaint by an additional 28 days to allow time to continue meet-and-confer efforts on the pleadings is
appropriate and beneficial, with the goal of avoiding expense and time of extensive litigation and/or a
Motion to Dismiss and/or Motion to Strike under FRCP 12(b)(6), 12(f), and the associated undue
consumption of the Court’s time.
Therefore, the Parties, by and through their respective counsel, hereby stipulate and agree that the
deadline for Defendants to file a responsive pleading to Plaintiff’s Complaint should be moved by 28 days
from December 10, 2025 to January 7, 2026.
IT IS SO STIPULATED
Dated: December 5, 2025 PORTER SCOTT
A PROFESSIONAL CORPORATION
By __________________________________
Derek J. Haynes
Steven E. Weiss
Attorneys for Defendant
COUNTY OF SACRAMENTO
Dated: December 5, 2025 SAMUEL and SAMUEL
By __________________________________
Peter F. Samuel
Attorney for Plaintiff
JOHNNY HER
Dated: December 5, 2025 ANGELO, KILDAY & KILDUFF, LLP
By __________________________________
Derick E. Konz
Attorney for Defendant
TRACEY JACOBS

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ORDER RE JOINT STIPULATION TO CONTINUE RESPONSIVE PLEADINGS DEADLINES
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A PROFESSIONAL CORPORATION
Derek J. Haynes, SBN 264621
dhaynes@porterscott.com
Steven E. Weiss, SBN 347790
sweiss@porterscott.com
2180 Harvard Street, Suite 500
Sacramento, California 95815
TEL: 916.929.1481
FAX: 916.927.3706
Attorneys for Defendant
COUNTY OF SACRAMENTO (erroneously sued as “COUNTY OF SACRAMENTO; SACRAMENTO COUNTY
SHERIFF’S DEPARTMENT”)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
JOHNNY HER,
Plaintiffs,
v.
COUNTY OF SACRAMENTO;
SACRAMENTO COUNTY SHERIFF’S
DEPARTMENT, a subsidiary of County of
Sacramento; TRACEY JACOBS; and DOES
1 through 50, inclusive,
Defendants. /
Case No.: 2:25−cv−2915−JDP
ORDER RE JOINT STIPULATION TO
CONTINUE RESPONSIVE PLEADINGS
DEADLINES
Good cause appearing therefore,
IT IS HEREBY ORDERED, per Stipulation by the Parties, that the deadline for Defendants to file a
responsive pleading to Plaintiffs’ Complaint should be moved by 28 days from December 10, 2025 to
January 7, 2026.
IT IS SO ORDERED.
Dated: December 5, 2025
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE