Singh v. Hauser et al

Filing 60

STIPULATION AND ORDER re 59 Stipulation filed by Mario Canton, John P. Morgan, Linda G. Hauser. Signed by Magistrate Judge Elizabeth D. Laporte on May 1, 2009. (edllc2, COURT STAFF) (Filed on 5/1/2009)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 KEKER & VAN NEST, LLP JON B. STREETER - #101970, jstreeter@kvn.com KHARI J. TILLERY - #215669, ktillery@kvn.com ROSE DARLING - #243893, rdarling@kvn.com 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Plaintiff RAGHBIR SINGH JOSEPH P. RUSSONIELLO ­ #44332 United States Attorney JOANN M. SWANSON - # 88143 Chief, Civil Division MICHAEL T. PYLE - # 172954, michael.t.pyle@usdoj.gov Assistant United States Attorney 450 Golden Gate Avenue 9th Floor, Box 36055 San Francisco, CA 94102-3495 Telephone (415) 436-7322 Facsimile: (415) 436-6748 Attorneys for Defendants LINDA HAUSER, MARIO CANTON & JOHN P. MORGAN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION RAGHBIR SINGH, Plaintiff, v. LINDA G. HAUSER, MARIO CANTON, JOHN P. MORGAN, NATIONAL COMMAND LINK NETWORK 20, AND DOES 1-25, Defendants. Case No. C-07-2997 EDL STIPULATION AND [PROPOSED] ORDER TO CONTINUE TIME TO COMPLETE SETTLEMENT Judge: The Hon. Elizabeth D. Laporte June 8, 2007 Date Comp. Filed: Trial Date: 438931.01 STIPULATION AND [PROPOSED] ORDER TO CONTINUE TIME TO COMPLETE SETTLEMENT Case No. C-07-2997 EDL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 RECITAL On August 4, 2008, the parties participated in a mediation session before Daniel Bowling and reached a settlement agreement. On September 18, 2008, the Court issued an order dismissing this case without prejudice, and with leave to reinstate on or before 90 days for the purpose of proceeding with the litigation in the event the parties did not complete the settlement prior to that date. On December 17, 2008, the Court granted the parties' stipulated request to extend the time to complete the settlement to January 30, 2009. On January 30, 3009, the Court granted another stipulated request to extend the time to complete settlement to March 31, 2009. On March 31, 2009, the Court granted another stipulated request to extend the time to complete settlement to April 30, 2009. The settlement has been finalized for several months. Since the last extension, all but one of the required signatories has signed the agreement. The only required signatory that has yet to sign the agreement, defendant J.P. Morgan, is no longer employed by the federal government. Further, Mr. Morgan is currently engaged in litigation against the government over a separate matter. The parties will, therefore, need some additional time to obtain Mr. Morgan's signature. The parties believe that the settlement will be finalized no later than June 30, 2009. STIPULATION For the foregoing reasons, plaintiff Singh and defendants Linda Hauser, Mario Canton, and John Morgan, through their undersigned counsel, stipulate and agree to extend the time to complete the settlement from April 30, 2009 to June 30, 2009. IT IS SO STIPULATED. 1 438931.01 STIPULATION AND [PROPOSED] ORDER TO CONTINUE TIME TO COMPLETE SETTLEMENT Case No. C-07-2997 EDL 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: April 30, 2009 KEKER & VAN NEST, LLP By: /s/ Khari J. Tillery KHARI J. TILLERY Attorneys for Plaintiff RAGHBIR SINGH Dated: April 30, 2009 JOSEPH P. RUSSONIELLO United States Attorney By: /s/ Michael T. Pyle [Concurrence Obtained General Order 45 § X.B] Assistant United States Attorney Attorneys for Defendants IT IS SO ORDERED. UNIT ED Dated:_May 1____, 2009 _____ S ISTRIC ES D TC AT T THE HONORABLE ELIZIBETH LAPORTE rte ER A N F D IS T IC T O R C 2 438931.01 STIPULATION AND [PROPOSED] ORDER TO CONTINUE TIME TO COMPLETE SETTLEMENT Case No. C-07-2997 EDL LI FO Judge E lizabeth D. Lapo R NIA IT IS S O ORD ERED RT U O NO RT H

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