Opinion
William J. Goines (SBN 61290), Greenberg Traurig, LLP, Stephen L. Saxl, (Not admitted in N.D. Cal.), Toby S. Soli, (Not admitted in N.D. Cal.), Greenberg Traurig, LLP, Attorneys for Defendants.
Philip J. Wang (SBN 218349), Justin S. Chang (SBN 205925), Wang & Chang, A Professional, Law Corporation, Attorneys for Plaintiff.
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT CONFERENCE
CLAUDIA WILKEN, District Judge.
Plaintiff and Defendants, by and through their respective undersigned counsel, stipulate and agree as follows:
WHEREAS, on June 2, 2011, the Court So Ordered the parties' initial stipulation extending the time for Defendants to respond to the Complaint in this action to July 11, 2011; and
WHEREAS, on July 8, 2011, the Court So Ordered the parties' second stipulation extending the time for Defendants to respond to the Complaint in this action through and including August 24, 2011; and
WHEREAS, on September 1, 2011, the Court So Ordered the parties' third stipulation extending the time for Defendants to respond to the Complaint in this action through and including September 23, 2011; and
WHEREAS, on September 29, 2011, the Court So Ordered the parties' fourth stipulation extending the time for Defendants to respond to the Complaint in this action through and including October 24, 2011; and
WHEREAS, on October 25, 2011, the Court So Ordered the parties' fifth stipulation extending the time for Defendants to respond to the Complaint in this action through and including November 23, 2011; and
WHEREAS the parties have now reached agreement on the terms of a settlement and anticipate filing a stipulation of dismissal within fourteen (14) days; and
WHEREAS, accordingly, Defendants have met and conferred with Plaintiff and requested an additional 30-day extension of the time for all Defendants to move against, answer or respond to the Complaint (through and including December 23, 2011), by which time the parties anticipate having filed a stipulation of dismissal; and
WHEREAS, Plaintiff has consented to Defendants' request; and
WHEREAS the Court had scheduled an initial Case Management Conference for November 29, 2011 at 2:00 p.m.; and
WHEREAS the parties believe that there will be no need for a Case Management Conference because a stipulation of dismissal will be filed within fourteen (14) days;
IT IS HEREBY STIPULATED, by and between Plaintiff and Defendants, through their respective counsel, and subject to Court approval, that the time for all Defendants to move against, answer or respond to the Complaint shall be extended from November 23, 2011 through and including December 23, 2011; and
IT IS FURTHER STIPULATED that the Case Management Conference scheduled for November 29, 2011 at 2:00 p.m. shall be adjourned.
In accordance with General Order 45 of the United States District Court for the Northern District of California, I attest that concurrence in the filing of this document has been obtained from the undersigned counsel.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED. A case management conference will be held on Wednesday, January 18, 2012, at 2:00 p.m.
ATTESTATION CLAUSE
I, William J. Goines, am the ECF User whose ID and password are being used to file this STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANTS TO RESPOND TO COMPLAINT AND ADJOURNING NOVEMBER 29, 2011 CASE MANAGEMENT CONFERENCE. In compliance with General Order 45, X.B., I hereby attest that Philip J. Wang has concurred in this filing.