Jackson Browne v. John McCain et al

Filing 82

STIPULATION for Extension of Time to Amend filed by Defendant John McCain. (Attachments: # 1 Proposed Order)(Bandlow, Lincoln)

Jackson Browne v. John McCain et al

Doc. 82

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LATHROP & GAGE LLP Lincoln D. Bandlow (SBN 170449) 1888 Century Park East, Suite 1000 Los Angeles, CA 90067-2627 Telephone: [phone] Fax: [phone] [e-mail] Attorneys for Defendant JOHN MCCAIN

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA JACKSON BROWNE., an individual Plaintiff, vs. JOHN MCCAIN, an individual; THE REPUBLICAN NATIONAL COMMITTEE, a non-profit political organization; THE OHIO REPUBLICAN PARTY, a non-profit political organization, Defendants. CASE # CV08-05334 RGK (Ex) STIPULATION TO EXTEND THE TIME TO AMEND THE PLEADINGS Hon. R. Gary Klausner Date Filed: August 14, 2008

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STIPULATION TO EXTEND TIME TO AMEND PLEADINGS

Dockets.Justia.com

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Defendants JOHN MCCAIN ("McCain") and the REPUBLICAN NATONAL COMMITTEE ("RNC") (collectively, "Defendants"), and Plaintiff JACKSON BROWNE ("Plaintiff"), by and through their undersigned attorneys, hereby state and stipulate as follows: WHEREAS, the last day on which a party may file a motion to amend pleadings and add additional parties in this matter is May 20, 2009; and WHEREAS, Plaintiff had intended to amend his Complaint to add another party as a co-defendant; and WHEREAS, the parties are currently very close to reaching a final settlement of this matter and are diligently working together to finalize the terms thereof so that a settlement agreement may be finalized in order to resolve this matter; and WHEREAS, extending the deadline to amend the pleadings to allow the parties to have time to finalize a settlement will promote judicial efficiency and preserve both party and judicial resources. THEREFORE, the parties stipulate that the time to amend the pleadings should be extended from May 20, 2009 until June 19, 2009. Dated: May 12, 2009 LATHROP & GAGE LLP

By:

Lincoln D. Bandlow

Attorneys for Defendant JOHN MCCAIN

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STIPULATION TO EXTEND TIME TO AMEND PLEADINGS

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DATED: May 12, 2009

KLEIN, ONEILL & SINGH LLP By: /s/ Howard J. Klein

Attorneys for Defendant THE REPUBLICAN NATIONAL COMMITTEE DATED: May 12, 2009 KINSELLA WEITZMAN ISER KUMP & ALDISERT LLP By: /s/ Lawrence Y. Iser

Attorneys for Plaintiff JACKSON BROWNE

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STIPULATION TO EXTEND TIME TO AMEND PLEADINGS