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

Filing 25

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 10/27/17: Defendants' request for a one-month extension to December 13, 2017, in which to file their responsive pleading(s) to the First Amended Complaint, and until Monday, January 8, 2018, for Plaintiff and Defendants to meet and confer concerning a discovery plan is GRANTED. (Kaminski, H)

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1 2 3 4 5 6 7 8 David R. Johanson (SBN 164141) HAWKINS PARNELL THACKSTON & YOUNG LLP 1776 Second Street Napa, California 94559 Telephone: (707) 299-2470 Facsimile: (707) 581-1704 djohanson@hptylaw.com 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 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION 10 11 12 13 14 15 16 17 18 19 20 21 22 ) ) ) Plaintiff, ) ) v. ) ) 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 ) RETIREMENT SAVINGS PLAN, AND ) TRUSTEES OF PRINCETON UNIVERSITY ) A/K/A PRINCETON BENEFITS COMMITTEE, ) ) ) 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 23 24 Defendants, Teachers Insurance Annuity Association Of America F/K/A Teachers Insurance 25 Annuity Association And College Retirement Equity Fund, Princeton University Monthly 26 Employees Retirement Plan, Princeton University Retirement Savings Plan, And Trustees Of 27 Princeton University A/K/A Princeton Benefits Committee (hereinafter, collectively, “Defendants”) 28 1 JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT AND MEET AND CONFER REGARDING DISCOVERY PLAN; ORDER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 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 October 18, 2017 Order [Dkt. 23] (this “Joint Stipulation”). Plaintiff and Defendants are in the process of memorializing settlement terms in a settlement agreement and general release, have exchanged drafts of same, and have essentially agreed upon its terms. There is a an additional issue that needs to be resolved. 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 November 13, 2017. [Dkt. 23.] Furthermore, Plaintiff and Defendants are required to meet and confer concerning a discovery plan on or before December 6, 2017. [Id.] Plaintiff and Defendants stipulate to and request a one-month extension for both deadlines, to December 13, 2017, to respond to the First Amended Complaint, and to Monday, January 8, 2018, 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 December 13, 2017, in which to file their responsive pleading(s) to the First Amended Complaint, and until Monday, January 8, 2018, for Plaintiff and Defendants to meet and confer concerning a discovery plan. Dated: November 13, 2017 Respectfully submitted, 20 21 22 23 HAWKINS PARNELL THACKSTON & YOUNG LLP By: /s/ David R. Johanson David R. Johanson 1776 Second Street Napa, California 94559 Telephone: (707) 299-2470 Facsimile: (707) 581-1704 24 25 26 Attorneys for Defendants 27 28 2 JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT AND MEET AND CONFER REGARDING DISCOVERY PLAN; ORDER 1 DOWNEY BRAND, LLP 2 By: 8 /s/ Annie S. Amaral Annie S. Amaral Tyson Ellery Hubbard Karina R. Stanhope 621 Capitol Mall Eighteenth Floor Sacramento, CA 95814-4686 916-520-5216 Fax: 916-520-5616 Email: thubbard@downeybrand.com aamaral@downeybrand.com kstanhope@downeybrand.com 9 Attorneys for Plaintiff 3 4 5 6 7 10 11 12 ORDER Pursuant to the stipulation of the parties, and good cause having been shown, Defendants’ 13 request for a one-month extension to December 13, 2017, in which to file their responsive 14 pleading(s) to the First Amended Complaint, and until Monday, January 8, 2018, for Plaintiff and 15 Defendants to meet and confer concerning a discovery plan is GRANTED. 16 17 IT IS SO ORDERED. Dated: November 27, 2017 18 19 20 21 22 23 24 25 26 27 28 3 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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