Lopez v. County of San Joaquin et al

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STIPULATION TO EXTEND TIME FOR DEFENDANTS COUNTY OF SAN JOAQUIN, PETER DEVENCENZI
AND GENEVIEVE VALLOTTON TO RESPOND TO PLAINTIFF’S AMENDED COMPLAINT
Mordaunt, Roundy,
Reihl & Jimerson
2800 W. March Lane,
Suite 300
Stockton, CA 95219
(209) 473-8732
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Lori A. Reihl, Esq., Bar No 246395
Curtis E. Jimerson, Esq., Bar No. 232054
Christopher J. Clark, Esq., Bar No. 346464
MORDAUNT, ROUNDY, REIHL & JIMERSON
A Professional Law Corporation
2800 W. March Lane, Suite 300
Stockton, CA 95219
Telephone: (209) 473-8732
Facsimile: (209) 957-9165
lreihl@mrrjlaw.com; cjimerson@mrrjlaw.com
cclark@mrrjlaw.com; service@mrrjlaw.com
Attorneys for Defendants
COUNTY OF SAN JOAQUIN; PETER DEVENCENZI
AND GENEVIEVE VALLOTTON
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
EMMANUEL LOPEZ
Plaintiff(s),
vs.
COUNTY OF SAN JOAQUIN, a
California municipal corporation; CITY
OF STOCKTON, a California municipal
corporation; PETER DEVENCENZI;
GENEVIEVE VALLOTTON, PHIRUN
VAR
Defendant(s).
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Case No. 2:25-CV-01792-WBS-CSK
STIPULATION TO EXTEND TIME FOR
DEFENDANTS COUNTY OF SAN JOAQUIN,
PETER DEVENCENZI AND GENEVIEVE
VALLOTTON TO RESPOND TO
PLAINTIFF’S FIRST AMENDED
COMPLAINT
Plaintiff EMMANUEL LOPEZ (“Plaintiff”), and defendants COUNTY OF SAN
JOAQUIN, PETER DEVENCENZI, and GENEVIEVE VALLOTTON, (“Defendants”), by and
through their undersigned counsel of record, stipulate and agree to extend the time for defendants
COUNTY OF SAN JOAQUIN, PETER DEVENCENZI, and GENEVIEVE VALLOTTON
to respond to Plaintiff’s First Amended Complaint (ECF, 18), as follows:
1. Plaintiff filed a First Amended Complaint on December 29, 2025 (ECF, 18), following
the order granting defendants’ Motion to Dismiss (ECF, 16) to plaintiff’s initial complaint in this
action;
2. Defendants COUNTY OF SAN JOAQUIN, PETER DEVENCENZI, and GENEVIEVE

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STIPULATION TO EXTEND TIME FOR DEFENDANTS COUNTY OF SAN JOAQUIN, PETER DEVENCENZI
AND GENEVIEVE VALLOTTON TO RESPOND TO PLAINTIFF’S AMENDED COMPLAINT
Mordaunt, Roundy,
Reihl & Jimerson
2800 W. March Lane,
Suite 300
Stockton, CA 95219
(209) 473-8732
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VALLOTTON’s current deadline to respond to the First Amended Complaint is January 12, 2026;
3. For purposes of efficiency and judicial economy Plaintiff and Defendants COUNTY OF
SAN JOAQUIN, PETER DEVENCENZI, and GENEVIEVE VALLOTTON, by and through their
undersigned counsel of record, have agreed to extend Defendants’ time to respond to Plaintiff’s
First Amended Complaint by 60 days to, March 13, 2026. Counsel for the parties to this stipulation
are informed and believe that plaintiff Emmanuel Lopez has passed away. Counsel for plaintiff is
in the process of contacting next of kin and preparing a Suggestion of Death pursuant to FRCP 25.
This extension will allow time for counsel and the parties to determine if this case will be dismissed
or for a motion for substitution to be prepared and heard, before responsive pleadings are due to the
First Amended Complaint.
4. There have not been any prior requests for extensions submitted by these defendants.
5. The parties, therefore, stipulate and agree that defendants COUNTY OF SAN
JOAQUIN, PETER DEVENCENZI, and GENEVIEVE VALLOTTON’s deadline to file their
response to the Complaint is extended to, and including, March 13, 2026.
IT IS SO STIPULATED AND AGREED.
Dated: January 5, 2026 SMITH LAW FIRM
By: /s/ Craig Smith
Craig R. Smith, Esq.
Attorney For Plaintiff
EMMANUEL LOPEZ
Dated: January 5, 2026 MORDAUNT, ROUNDY, REIHL & JIMERSON
By: /s/ Lori Reihl
Lori A. Reihl, Esq.
Attorneys for Defendants
COUNTY OF SAN JOAQUIN, PETER
DEVENCENZI AND GENEVIEVE
VALLOTTON

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STIPULATION TO EXTEND TIME FOR DEFENDANTS COUNTY OF SAN JOAQUIN, PETER DEVENCENZI
AND GENEVIEVE VALLOTTON TO RESPOND TO PLAINTIFF’S AMENDED COMPLAINT
Mordaunt, Roundy,
Reihl & Jimerson
2800 W. March Lane,
Suite 300
Stockton, CA 95219
(209) 473-8732
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ORDER
GOOD CAUSE APPEARING THEREFORE, and pursuant to the stipulation of the parties,
the Stipulation to Extend Time for Defendants COUNTY OF SAN JOAQUIN, PETER
DEVENCENZI, and GENEVIEVE VALLOTTON to respond to Plaintiff’s First Amended
Complaint is APPROVED.
IT IS HEREBY ORDERED that defendants COUNTY OF SAN JOAQUIN, PETER
DEVENCENZI, and GENEVIEVE VALLOTTON’s deadline to file their response to the
Complaint is extended to, and including, March 13, 2026.
Dated: January 6, 2026