Opinion
ROMAN OTKUPMAN, OTKUPMAN LAW FIRM, A LAW CORPORATION, Woodland Hills, CA, Attorneys for Plaintiff Pakiza A. Ali.
KELSEY E. PAPST, LITTLER MENDELSON, P.C., Sacramento, CA, Attorneys for Defendant Rainbow USA, Inc.
JOINT STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF TO FILE A MOTION TO REMAND CASE TO STATE COURT
JOHN A. MENDEZ, District Judge.
Plaintiff PAKIZA A. ALI ("Plaintiff") and Defendant RAINBOW USA INC. ("Defendant") hereby stipulate and agree that Plaintiff's deadline to file a motion to remand the instant case on the basis of any defect other than lack of subject matter jurisdiction pursuant to 28 U.S.C. § 1447(c) be extended by 30 days as follows:
WHEREAS, on or around February 24, 2015, Defendant removed the instant action to District Court;
WHEREAS, Plaintiff intends to file a Motion to Remand this case to State Court;
WHEREAS, the deadline to file a Motion to Remand is March 25, 2015;
WHEREAS, Defendant intends to oppose Plaintiff's Motion to Remand;
WHEREAS, the Parties are currently discussing settlement of the entire case but need additional time to schedule a private mediation and to conduct certain limited, informal discovery in conjunction with that mediation; and
WHEREAS, in order to save both parties on costs and fees in filing and opposing the Plaintiff's Motion to Remand, the parties need more time to assess the settlement of the entire case.
THEREFORE, the Parties to the above-captioned matter hereby stipulate and agree as follows:
1. Plaintiff's deadline to file her Motion to Remand to be extended by thirty (30) days.
2. The new deadline for Plaintiff to file her Motion to Remand will be April 24, 2015.
IT IS SO STIPULATED ON THE DATES INDICATED BELOW.
ORDER
Good cause appearing, and pursuant to the stipulation of the parties, IT IS HEREBY ORDERED that:
1. Plaintiff's deadline to file her Motion to Remand to be extended by thirty (30) days.
2. The new deadline for Plaintiff to file her Motion to Remand will be April 24, 2015.