Fox v. Bakery, Confectionery, Tobacco Workers and Grain Millers International Union, Local No. 24, AFL-CIO et al

Filing 60

STIPULATION AND ORDER EXTENDING PAGE LIMITATIONS WITH MODIFICATIONS. Signed by Judge Alsup on December 9, 2009. (whalc1, COURT STAFF) (Filed on 12/9/2009)

Download PDF
Case3:08-cv-05737-WHA Document59 Filed12/09/09 Page1 of 3 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 JEFFREY FREUND (SBN 47846) BREDHOFF & KAISER, PLLC 805 15th St. NW Washington, DC 20005 Telephone: (202) 842-2600 Facsimile: (202) 842-1888 jfreund@bredhoff.com DUANE B. BEESON (SBN 20215) ANDREW H. BAKER (SBN 104197) BEESON, TAYER & BODINE, APC 1404 Franklin Street, 5th Floor Oakland, CA 94612-3208 Telephone: (510) 625-9700 Facsimile: (510) 625-8275 Email: dbeeson@beesontayer.com Counsel for Defendants BCTWU Local 24 and Felisa Castillo PETER D. NUSSBAUM (SBN 49682) PETER E. LECKMAN (SBN 235721) ALTSHULER BERZON LLP 177 Post Street, Suite 300 San Francisco, CA 94108 Telephone: (415) 421-7151 Facsimile: (415) 362-8064 pnussbaum@altshulerberzon.com pleckman@altshulerberzon.com Counsel for Defendants Bakery, Confectionery, Tobacco Workers and Grain Millers International Union, AFL-CIO and Randy Roark JEFFREY RYAN (SBN 129079) RYAN & STEINER An Association of Attorneys 455 North Whitman Road, Suite 200 Mountain View, CA 94043-5721 Telephone: (650)691-1430 Facsimile: (650) 968-2685 jr@ryansteiner.com Counsel for Plaintiff Alexander Fox UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ALEXANDER FOX, Plaintiff, v. BAKERY, CONFECTIONERY, TOBACCO WORKERS and GRAIN MILLERS INTERNATIONAL UNION, LOCAL NO. 24, AFL-CIO; BAKERY, CONFECTIONERY, TOBACCO WORKERS and GRAIN MILLERS INTERNATIONAL UNION, AFL-CIO; FELISA CASTILLO, an individual; and RANDY ROARK, an individual, Defendants. CASE NO. CV-08-05737 WHA STIPULATION TO EXTEND PAGE LIMITATIONS OF CIVIL L.Rs. 7.2(a) and 7.4(b) AND ORDER WITH MODIFICATIONS Judge: Hon. William Alsup 1 STIPULATION TO EXTEND PAGE LIMITATIONS Case No. CV-08-05737 WHA Case3:08-cv-05737-WHA Document59 Filed12/09/09 Page2 of 3 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 The parties hereto hereby stipulate to an extension of the page limitations contained in Civil L.Rs. 7-2(a) and 7-4(b), to permit the Defendants to file Motions for Summary Judgment with incorporated Memorandum of Points and Authorities, and the Plaintiff to file Oppositions to such motions, each of up to 30 pages in length. Civil L.Rs. 7-2(a) and 7-4(b) provide that motions and their incorporated briefs or memoranda of points and authorities shall not exceed 25 pages of text. Mindful of those rules, and recognizing that it is always important to keep briefs as concise as possible, Defendants BCTGM and Roark have prepared a draft motion for summary judgment. Although under the Rules, Defendant BCTGM and Roark could each file a brief of up to 25 pages, they will be filing a joint brief. In drafting the joint brief, they have found that one marginally longer than 25 pages is necessary in order for them to adequately present the reasons why they believe summary judgment should be granted on the entirety of Plaintiff's case. While the facts of this case are not particularly complicated, Plaintiff's Second Amended Complaint sets forth six different legal theories under which Plaintiff claims he is entitled to relief. Under these circumstances, Defendants BCTGM and Roark have found that 30 pages are needed in order to present their arguments, and it is also appropriate that Plaintiff should have the same page limits in which to oppose Defendants' motions. Thus, the parties have consulted and have agreed that it is reasonable for Defendants' Motions for Summary Judgment and Plaintiff's Oppositions to such motions to be up to 30 pages in length. The parties further agree that they will comply with the 15-page limitation of Civil L.R. 7-4(b) for their Reply briefs. For these reasons, it is hereby stipulated as follows: 1. The parties respectfully request that the Court grant leave to permit the Defendants to file Motions for Summary Judgment of up to 30 pages in length, and the Plaintiff to file Oppositions to such motions of up to 30 pages in length. 1 STIPULATION TO EXTEND PAGE LIMITATIONS Case No. CV-08-05737 WHA Case3:08-cv-05737-WHA Document59 Filed12/09/09 Page3 of 3 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 2 STIPULATION TO EXTEND PAGE LIMITATIONS Case No. CV-08-05737 WHA Dated: December 9, 2009 ___________/S/____________ JEFFREY FREUND BREDHOFF & KAISER, PLLC 805 15th St. NW Washington, DC 20005 _________/S/______________ DUANE B. BEESON ANDREW H. BAKER BEESON, TAYER & BODINE, APC Counsel for Defendants BCTWU Local 24 and Felisa Castillo __________/S/______________ PETER D. NUSSBAUM PETER E. LECKMAN ALTSHULER BERZON LLP 177 Post Street, Suite 300 San Francisco, CA 94108 Counsel for Defendants Bakery, Confectionery, Tobacco Workers and Grain Millers International Union, AFL-CIO and Randy Roark ________/S/__________________ JEFFREY RYAN RYAN & STEINER An Association of Attorneys 455 North Whitman Road, Suite 200 Mountain View, CA 94043-5721 Counsel for Plaintiff Alexander Fox IT IS HEREBY ORDERED that the 30-page limit applies only to joint summary judgment briefs filed by two or more defendants, and any briefs filed in opposition thereto. [PROPOSED] ORDER Summary judgment motions filed by single defendants (and oppositions filed in response) must comply with the 25 page limit. December 9 Dated: ____________, 2009 CT ES ________________ C AT T WILLIAM ALSUP UNITED STATES DISTRICT JUDGE DERED DISTRI RT U O UNIT ED S ER N F D IS T IC T O R A C LI FO Judge W lsup illiam A R NIA IT IS S O OR NO RT H

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?