govinfo:USCOURTS-caed-2_25-cv-03381-0

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BUCHALTER LLP 
SACRAMENTO 
 
 
SECOND STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADING 

BUCHALTER 110739223v1 
BUCHALTER LLP 
Josh H. Escovedo, State Bar No. 284506 
jescovedo@buchalter.com 
Emily G. Malhiot, State Bar No. 330082 
emalhiot@buchalter.com 
500 Capitol Mall, Suite 1900 
Sacramento, CA 95814 
Telephone: 916.945.5170 
 
Attorneys for Defendants 
Sourcis, Inc., dba Mexico Bariatric Center, 
and Shahram Elli, Ph.D. 
UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF CALIFORNIA 
SACRAMENTO DIVISION 
TAD ROEMELING and AUSTIN 
ROEMELING, 
Plaintiffs, 
vs. 
SOURCIS, INC., DBA MEXICO BARIATRIC 
CENTER; MEXICO BARIATRIC CENTER; 
SHAHRAM ELLI, PH.D.; HOSPITAL AZAR; 
AZAR SPECIALTY HOSPITAL; DR. JESUS 
DE JESUS CEJA ESQUIVEZ, and DOES 1 
through 100, inclusive, 
Defendants. 

 
SECOND STIPULATION AND ORDER 
TO EXTEND TIME TO FILE 
RESPONSIVE PLEADING (ECF No.7) 
 Pursuant to Eastern District Local Rule 144(a), Plaintiffs Tad Roemeling and Austin 
Roemeling and Defendants Sourcis, Inc., dba Mexico Bariatric Center, and Shahram Elli, Ph.D. 
(collectively, “Sourcis Defendants”), by and through their respective counsel of record, stipulate 
as follows: 
1. Plaintiffs filed this action on November 20, 2025. 
2. Plaintiffs served Sourcis Defendants with the waivers of service of summons on 
March 6, 2026. 
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BUCHALTER LLP 
SACRAMENTO 
 
 2 
SECOND STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADING 

BUCHALTER 110739223v1 
3. Pursuant to a prior stipulation between the Parties, the responsive pleading 
deadline was continued to June 2, 2026. Because the stipulation was made under Eastern District 
Local Rule 144(a), the Court need not approve that stipulation. 
4. Despite diligent efforts, counsel for Sourcis Defendants have been unable to 
communicate with their clients. As a result, counsel will file a Motion to Withdraw as Counsel of 
Record to be heard on July 14, 2026. Counsel for Sourcis Defendants have notified Plaintiffs’ 
counsel of this development. 
5. There are no other pending deadlines in this case that would be affected by the 
request for extension. 
6. Accordingly, the Parties agree that Sourcis Defendants will now have until July 
28, 2026 to file a responsive pleading to Plaintiffs’ Complaint. 
IT IS SO STIPULATED. 
 
DATED: June 4, 2026 BUCHALTER LLP 
By: 
Emily G. Malhiot 
Attorneys for Defendants 
Sourcis, Inc., dba Mexico Bariatric Center, 
and Shahram Elli, Ph.D. 
 
DATED: June 4, 2026 SCHULTZ LAW GROUP, PC 
By: 
Steven H. Schultz 
Attorney for Plaintiffs 
Tad Roemeling and Austin Roemeling 
 
 
/s/ EMILY MALHIOT 
/S/ STEVEN H. SCHULTZ 

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BUCHALTER LLP 
SACRAMENTO 
 
 3 
SECOND STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADING 

BUCHALTER 110739223v1 
ORDER 
Pursuant to the stipulation of the Parties, and good cause appearing therefor, Defendants 
Sourcis, Inc. dba Mexico Bariatric Center and Shahram Elli shall have until July 28, 2026, to file 
their responsive pleading to Plaintiffs’ Complaint. 
IT IS SO ORDERED. 
 
Dated: June 05, 2026 
 
 

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