Opinion
CASE NO. 08-cv-05097-WHA
11-09-2011
SANTA CLARA VALLEY HOUSING GROUP, INC. and KRISTEN M. BOWES, Plaintiffs, v. UNITED STATES OF AMERICA Defendant.
STEVEN TOSCHER, State Bar No. 91115 CHARLES P. RETTIG, State Bar No. 97848 AVRAM SALKIN, State Bar No. 30412 EDWARD M. ROBBINS, JR., State Bar No. 82696 SHARYN M. FISK, State Bar No. 199898 Hochman Salkin Rettig Toscher & Perez, P.C. Attorneys for Plaintiffs Santa Clara Valley Housing Group, Inc. and Kristen M. Bowes MELINDA L. HAAG United States Attorney THOMAS M. NEWMAN Assistant United States Attorney HENRY C. DARMSTADTER JAMES E. WEAVER ADAM D. STRAIT Attorneys for the United States of America
STEVEN TOSCHER, State Bar No. 91115
CHARLES P. RETTIG, State Bar No. 97848
AVRAM SALKIN, State Bar No. 30412
EDWARD M. ROBBINS, JR., State Bar No. 82696
SHARYN M. FISK, State Bar No. 199898
Hochman Salkin Rettig Toscher & Perez, P.C.
Attorneys for Plaintiffs Santa Clara Valley Housing Group, Inc. and Kristen M. Bowes
MELINDA L. HAAG
United States Attorney
THOMAS M. NEWMAN
Assistant United States Attorney
HENRY C. DARMSTADTER
JAMES E. WEAVER
ADAM D. STRAIT
Attorneys for the United States of America
JOINT STIPULATION TO EXTEND TIME TO FILE DEFENDANT'S OPPOSITION, AND PLAINTIFF'S REPLY, TO MOTION FOR RECONSIDERATION, AND [PROPOSED] ORDER
SANTA CLARA VALLEY HOUSING GROUP, INC. ("Santa Clara"), and KRISTEN M. BOWES ("Bowes") (collectively referred to as "Plaintiffs") and the UNITED STATES OF AMERICA ("Defendant"), by and through their attorneys, hereby request that the deadlines for (1) Defendant to file an opposition to Plaintiff's motion for reconsideration, and (2) Plaintiff Santa Clara to file a reply to Defendant's opposition, be extended for a short time (approximately one week) as set forth below. In support of this Stipulation, the parties state as follows:
1. On February 14, 2011, the parties filed cross motions for summary judgment.
2. On July 19, 2011, the Court heard oral argument on the motions.
3. On September 21, 2011, the Court issued an order with respect to the cross motions for summary judgment in which the Court: (1) granted Defendant's motion for partial summary judgment; (2) denied Santa Clara's motion for summary judgment; and (3) granted, in part, and denied, in part, Bowes' motion for summary judgment.
4. On October 7, 2011, Santa Clara moved for leave to file a motion for reconsideration of the Court's September 21, 2011 order.
5. On November 1, 2011, the Court granted Santa Clara's motion for leave to file a motion for reconsideration of the Court's order. (Doc. 108). The Court set deadlines for the Defendant to file an opposition by November 14, 2011 and for the Plaintiff to file a reply by November 21, 2011.
6. Due to scheduling obligations with respect to other matters, counsel for the parties are seeking very brief extensions of the deadlines established by the Court in its order of November 1, 2011.
7. The parties hereby stipulate and request that the deadlines be revised so that the Defendant may file its opposition to Santa Clara's motion for reconsideration by November 21, 2011.
8. The parties further stipulate and request that the deadlines be revised so that the Plaintiff may file a reply to Defendant's opposition by November 30, 2011.
HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C.
SHARYN M. FISK
Hochman, Salkin, Rettig, Toscher & Perez, P.C.
Attorney for SANTA CLARA VALLEY HOUSING GROUP, INC. and KRISTEN M. BOWES
UNITED STATES DEPARTMENT OF JUSTICE
HENRY C. DARMSTADTER
JAMES E. WEAVER
ADAM STRAIT
Attorneys for the UNITED STATES OF AMERICA
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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UNITED STATES DISTRICT JUDGE