Hamidi et al v. Service Employees International Union Local 1000 et al

Filing 9

STIPULATION and ORDER 8 for extension of time signed by Judge Garland E. Burrell, Jr. on 2/25/2014. Defendants have until and including 4/25/2014 to file a responsive pleading to the 1 Complaint. (Marciel, M)

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JEFFREY B. DEMAIN (SBN 126715)
Altshuler Berzon LLP
177 Post Street, Suite 300
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
J. FELIX DE LA TORRE (SBN 204282)
ANNE M. GIESE (SBN 143934)
SEIU Local 1000
1808 14th Street
Sacramento, California 95811
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
Service Employees International Union, Local 1000

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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KOUROSH KENNETH HAMIDI, et al., AND )
THE CLASS THEY SEEK TO REPRESENT )
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Plaintiffs,
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v.
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SERVICE EMPLOYEES INTERNATIONAL )
UNION, LOCAL 1000, et al.;
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Defendants.
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_______________________________________ )

No. 2:14-cv-00319-GEB-KJN
STIPULATED REQUEST FOR
EXTENSION OF TIME TO RESPOND TO
COMPLAINT; [PROPOSED] ORDER
THEREON

Hearing Date:
Time:
Courtroom:
Judge:

N/A
N/A
N/A
Hon. Garland E. Burrell, Jr.

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STIP. REQUEST FOR EXT. OF TIM E TO RESPOND TO COM PLAINT; [PROPOSED] ORDER THEREON
Hamidi, et al. v. SEIU Local 1000, et al., Case No. 2:14-cv-00319-GEB-KJN

STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

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The parties to the above-captioned case, by and through their undersigned counsel of record,

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hereby respectfully request that defendants be granted until and including April 25, 2014, to respond to

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plaintiffs’ Complaint. In support of that request, the parties state as follows:

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1. The responsive pleading on behalf of defendant John Chiang, Controller of the State of

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California, is currently due on February 24, 2014. The requested extension until and including April 25,

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2014 will afford Secretary Chiang a sixty-day extension of time to respond to the Complaint.
2. The responsive pleading on behalf of the other defendant in this case, Service Employees

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International Union Local 1000, is currently due on March 4, 2014. The requested extension until and
including April 25, 2014 will afford Local 1000 a fifty-two-day extension of time to respond to the
Complaint.

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3. No previous extensions of time to respond to the Complaint have been requested or granted in
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this case.
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4. The requested extension of time is necessary because defendants have only recently secured
counsel to represent them in this case, plaintiffs’ Complaint contains numerous factual allegations that
counsel must investigate in order to prepare responsive pleadings, and defendants’ counsel have
numerous litigation commitments that will require their attention in the next sixty days.

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5. The requested extension of time will not require the Court to reschedule any pretrial dates

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previously scheduled in this case.

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STIP. REQUEST FOR EXT. OF TIM E TO RESPOND TO COM PLAINT; [PROPOSED] ORDER THEREON
Hamidi, et al. v. SEIU Local 1000, et al., Case No. 2:14-cv-00319-GEB-KJN

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The foregoing is hereby stipulated among the parties in this action, who respectfully request the

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Court to grant the extension of time.
Dated: February 20, 2014.

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Respectfully submitted,

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JEFFREY B. DEMAIN
Altshuler Berzon LLP

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J. FELIX DE LA TORRE
ANNE M. GIESE
SEIU Local 1000

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By:

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/s/ Jeffrey B. Demain
Jeffrey B. Demain

Attorneys for Defendant Service Employees International
Union, Local 1000

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Kim L. Nguyen (SBN 209524; application for admission
pending)
Deputy Attorney General
Government Law Section
Department of Justice, Office of the Attorney General
300 South Spring Street, Suite 1702
Los Angeles, California 90013
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]

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Mark Beckington (SBN 126009)
Supervising Deputy Attorney General
California Department of Justice
300 South Spring Street, Suite 1702
Los Angeles, California 90013
Tel.: [phone]
Fax: [phone]
E-mail: [e-mail]

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By: /s/ Mark Beckington (as authorized on Feb. 20, 2014)
Mark Beckington

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Attorneys for Defendant John Chiang, Controller of the
State of California

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STIP. REQUEST FOR EXT. OF TIM E TO RESPOND TO COM PLAINT; [PROPOSED] ORDER THEREON
Hamidi, et al. v. SEIU Local 1000, et al., Case No. 2:14-cv-00319-GEB-KJN

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W. JAMES YOUNG, Esq. (pro hac vice application
pending)
c/o National Right to Work Legal Defense Foundation, Inc.
8001 Braddock Road, Suite 600
Springfield, Virginia 22160
[phone]

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STEVEN R. BURLINGHAM, Esq.
California Bar No. 88544
Gary, Till & Burlingham
5330 Madison Avenue, Suite F
Sacramento, California 95841
[phone]
Facsimile — [phone]

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By: /s/ W. James Young (as authorized on Feb. 20 , 2014)
W. James Young

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Attorneys for Plaintiffs and the Class They
Seek to Represent

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[PROPOSED] ORDER

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IT IS SO ORDERED.

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Dated: February 25, 2014

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GARLAND E. BURRELL, JR.
Senior United States District Judge

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STIP. REQUEST FOR EXT. OF TIM E TO RESPOND TO COM PLAINT; [PROPOSED] ORDER THEREON
Hamidi, et al. v. SEIU Local 1000, et al., Case No. 2:14-cv-00319-GEB-KJN

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