Weatherwax v. Teachers Ins. Annuity Assoc., et al.,

Filing 23

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 10/17/2017 GRANTING Defendant's Extension of Time to respond to First Amended Complaint until 11/13/2017 and for parties to meet and confer regarding a discovery plan until 12/6/2017. (Hunt, G)

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David R. Johanson (SBN 164141)
HAWKINS PARNELL THACKSTON & YOUNG LLP
1776 Second Street
Napa, California 94559
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants,
TEACHERS INSURANCE ANNUITY ASSOCIATION
OF AMERICA, PRINCETON UNIVERSITY MONTHLY
EMPLOYEES RETIREMENT PLAN, PRINCETON
UNIVERSITY RETIREMENT SAVINGS PLAN AND
THE TRUSTEES OF PRINCETON UNIVERSITY

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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)
)
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Plaintiff,
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v.
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TEACHERS INSURANCE ANNUITY
)
ASSOCIATION OF AMERICA F/K/A
)
TEACHERS INSURANCE ANNUITY
)
ASSOCIATION AND COLLEGE RETIREMENT)
EQUITY FUND, PRINCETON UNIVERSITY )
MONTHLY EMPLOYEES RETIREMENT
)
PLAN, PRINCETON UNIVERSITY
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RETIREMENT SAVINGS PLAN, AND
)
TRUSTEES OF PRINCETON UNIVERSITY
)
A/K/A PRINCETON BENEFITS COMMITTEE, )
)
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Defendants
LESLIE WEATHERWAX,

Case No.: 2:17-cv-01050-MCE-KJN
JOINT STIPULATION FOR EXTENSION
OF TIME FOR DEFENDANTS TO
RESPOND TO FIRST AMENDED
COMPLAINT AND FOR PARTIES TO
MEET AND CONFER REGARDING A
DISCOVERY PLAN; ORDER

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Defendants, Teachers Insurance Annuity Association Of America F/K/A Teachers Insurance

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Annuity Association And College Retirement Equity Fund, Princeton University Monthly

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Employees Retirement Plan, Princeton University Retirement Savings Plan, And Trustees Of

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Princeton University A/K/A Princeton Benefits Committee (hereinafter, collectively, “Defendants”)

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JOINT STIPULATION FOR EXTENSION OF TIME FOR
DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT AND
MEET AND CONFER REGARDING DISCOVERY PLAN; ORDER

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and Plaintiff Leslie Weatherwax hereby stipulate and agree to an additional extension of time for
Defendants to respond to the First Amended Complaint and for an extension of the deadlines
contained within this Court’s May 18, 2017, Initial Pretrial Scheduling Order [Dkt. 4], as modified
by this Court’s September 19, 2017 Order [Dkt. 21] (this “Joint Stipulation”).
Plaintiff and Defendants are in the process of memorializing settlement terms in a settlement
agreement and general release, and have exchanged drafts of same. Because of the number of
parties involved, this process has taken more time than initially foreseen. The parties do not foresee
any complications in finalizing their settlement.
Defendants are presently required to respond to the First Amended Complaint no later than
October 13, 2017. [Dkt. 21.] Furthermore, Plaintiff and Defendants are required to meet and confer
concerning a discovery plan on or before Monday, November 6, 2017. [Id.] Plaintiff and
Defendants stipulate to and request a one-month extension for both deadlines, to Monday, November
13, 2017, to respond to the First Amended Complaint, and to Wednesday, December 6, 2017, for
Plaintiff and Defendants to meet and confer concerning a discovery plan.
WHEREFORE, Defendants, with the consent of Plaintiff, respectfully request this Court to
grant to Defendants a one-month extension to Monday, November 13, 2017, in which to file their
responsive pleading(s) to the First Amended Complaint, and until Wednesday, December 6, 2017,
for Plaintiff and Defendants to meet and confer concerning a discovery plan.
Dated: October 9, 2017

Respectfully submitted,

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HAWKINS PARNELL
THACKSTON & YOUNG LLP
By:

/s/ David R. Johanson
David R. Johanson
1776 Second Street
Napa, California 94559
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants

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JOINT STIPULATION FOR EXTENSION OF TIME FOR
DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT AND
MEET AND CONFER REGARDING DISCOVERY PLAN; ORDER

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DOWNEY BRAND, LLP

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By:

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/s/ Tyson Ellery Hubbard
Tyson Ellery Hubbard
Annie S. Amaral
Karina R. Stanhope
621 Capitol Mall
Eighteenth Floor
Sacramento, CA 95814-4686
916-520-5216
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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ORDER

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Pursuant to the stipulation of the parties, and good cause having been shown, Defendants’
request for a one-month extension to Monday, November 13, 2017, in which to file their responsive
pleading(s) to the First Amended Complaint, and until Wednesday, December 6, 2017, for Plaintiff
and Defendants to meet and confer concerning a discovery plan is GRANTED.
IT IS SO ORDERED.

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Dated: October 17, 2017

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JOINT STIPULATION FOR EXTENSION OF TIME FOR
DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT AND
MEET AND CONFER REGARDING DISCOVERY PLAN; ORDER