Veterans for Common Sense et al v. Nicholson et al

Filing 108

STIPULATION AND [PROPOSED] ORDER Request to Extend Time for Opposition by Veterans United for Truth, Inc, Veterans for Common Sense. (Moser, Heather) (Filed on 1/31/2008) Modified on 2/1/2008 (aaa, Court Staff).

Download PDF
Veterans for Common Sense et al v. Nicholson et al Doc. 108 1 2 3 4 5 6 7 8 9 10 11 GORDON P. ERSPAMER (CA SBN 83364) GErspamer@mofo.com MORRISON & FOERSTER LLP 101 Ygnacio Valley Road, Suite 450 P.O. Box 8130 Walnut Creek, California 94596-8130 Telephone: 925.295.3300 Facsimile: 925.946.9912 SIDNEY M. WOLINSKY (CA SBN 33716) SWolinsky@dralegal.org JENNIFER WEISER BEZOZA (CA SBN 247548) JBezoza@dralegal.org KATRINA KASEY CORBIT (CA SBN 237931) KCorbit@dralegal.org DISABILITY RIGHTS ADVOCATES 2001 Center Street, Third Floor Berkeley, California 94704-1204 Telephone: 510.665.8644 Facsimile: 510.665.8511 [see next page for additional counsel for Plaintiffs] 12 13 14 15 16 17 18 19 Plaintiffs, 20 v. 21 22 23 24 25 26 27 28 Case No. C-07-3758-SC STIPULATED REQUEST TO EXTEND TIME sf-2460591 FOR OPPOSITION TO MOTION TO DISMISS GREENE AND MUKASEY Attorneys for Plaintiffs VETERANS FOR COMMON SENSE and VETERANS UNITED FOR TRUTH, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION VETERANS FOR COMMON SENSE, and VETERANS UNITED FOR TRUTH, INC., Case No. C-07-3758-SC CLASS ACTION STIPULATED REQUEST TO EXTEND TIME FOR OPPOSITION TO DEFENDANTS' MOTION TO DISMISS CLAIMS AGAINST DEFENDANTS WILLIAM P. GREENE, JR. AND MICHAEL B. MUKASEY Complaint Filed July 23, 2007 JAMES B. PEAKE, M.D., Secretary of Veterans Affairs, et al., Defendants. Dockets.Justia.com 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 ADDITIONAL COUNSEL FOR PLAINTIFFS: ARTURO J. GONZALEZ (CA SBN 121490) AGonzalez@mofo.com HEATHER A. MOSER (CA SBN 212686) HMoser@mofo.com STACEY M. SPRENKEL (CA SBN 241689) SSprenkel@mofo.com PAUL J. TAIRA (CA SBN 244427) PTaira@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522 BILL D. JANICKI (CA SBN 215960) WJanicki@mofo.com MORRISON & FOERSTER LLP 400 Capitol Mall, Suite 2600 Sacramento, California 95814 Telephone: 916.448.3200 Facsimile: 916.448.3222 Case No. C-07-3758-SC STIPULATED REQUEST TO EXTEND TIME sf-2460591 FOR OPPOSITION TO MOTION TO DISMISS GREENE AND MUKASEY 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 WHEREAS on January 18, 2008, Defendants filed a Motion to Dismiss Claims Against Defendants William P. Greene, Jr. and Michael B. Mukasey; WHEREAS the date for Plaintiffs' response to the Motion to Dismiss is February 1, 2008; WHEREAS Plaintiffs anticipate that they will require one extra week to file their memorandum in opposition to the Motion to Dismiss as a result the recent health issues experienced by the attorney primarily responsible for drafting the opposition, Heather Moser, in addition to the numerous other filings due during the same time period; WHEREAS Plaintiffs are evaluating whether they wish to pursue these claims and require an additional week in which to do so; WHEREAS Defendants anticipate that they will require a week to file their reply brief in support of the Motion to Dismiss, as allowed under the Civil Local Rules for the Northern District of California; and WHEREAS the parties have agreed to a mutual extension of time for the opposition to the Motion to Dismiss and the reply in support of the Motion to Dismiss; IT IS HEREBY STIPULATED by and between the parties to this action, through their counsel of record, as follows: 1. Plaintiffs' memorandum in opposition to Defendants' Motion to Dismiss Claims Against Defendants William P. Greene, Jr. and Michael B. Mukasey shall be due on February 8, 2008. 2. Defendants' reply memorandum of points and authorities in support of the motion for a protective order to stay discovery shall be due on February 15, 2008. 3. The hearing date will be moved to February 29, 2008, the same date currently set for the hearing on Defendants' Motion for Protective Order to Stay Discovery from the U.S. Court of Appeals for Veterans Claims. Case No. C-07-3758-SC STIPULATED REQUEST TO EXTEND TIME sf-2460591 FOR OPPOSITION TO MOTION TO DISMISS GREENE AND MUKASEY 1 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: January 31, 2008 GORDON P. ERSPAMER ARTURO J. GONZALEZ HEATHER A. MOSER BILL D. JANICKI STACEY M. SPRENKEL PAUL J. TAIRA MORRISON & FOERSTER LLP By: /s/ Heather A. Moser Heather A. Moser Attorneys for Plaintiffs Dated: January 31, 2008 PETER D. KEISLER SCOTT N. SCHOOLS RICHARD LEPLEY DANIEL BENSING STEVEN Y. BRESSLER KYLE R. FREENY UNITED STATES DEPARTMENT OF JUSTICE By: /s/ Daniel Bensing Daniel Bensing Attorneys for Defendants I, Heather A. Moser, am the ECF User whose ID and password are being used to file this Stipulated Request to Extend Time for Opposition to Motion for Protective Order to Stay Discovery and Reply Memorandum in Support of Motion for Protective Order to Stay Discovery. In compliance with General Order 45, X.B., I hereby attest that Daniel Bensing has concurred in this filing. Dated: January 31, 2008 MORRISON & FOERSTER LLP By: /s/ Heather A. Moser Heather A. Moser Attorneys for Plaintiffs Case No. C-07-3758-SC STIPULATED REQUEST TO EXTEND TIME sf-2460591 FOR OPPOSITION TO MOTION TO DISMISS GREENE AND MUKASEY 2 1 2 3 4 DATED: 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. C-07-3758-SC STIPULATED REQUEST TO EXTEND TIME sf-2460591 FOR OPPOSITION TO MOTION TO DISMISS GREENE AND MUKASEY PURSUANT TO STIPULATION, IT IS SO ORDERED. THE HONORABLE SAMUEL CONTI UNITED STATES DISTRICT COURT JUDGE 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?