Siraj v. Bayer HealthCare LLC

Filing 35

ORDER granting continuance re 34 (tf, COURT STAFF) (Filed on 11/10/2009)

Case3:09-cv-00233-SI Document34

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MELINDA S. RIECHERT, State Bar No. 065504 MICHELLE A. GRIFFITH-JONES, State Bar No. 259914 MORGAN, LEWIS & BOCKIUS LLP 2 Palo Alto Square 3000 El Camino Real, Suite 700 Palo Alto, CA 94306-2122 Tel: [phone] Fax: [phone] Email: [e-mail] [e-mail] Attorneys for Defendant BAYER HEALTHCARE LLC KENNETH C. ABSALOM, State Bar No. 114607 LAW OFFICES OF NEVIN & ABSALOM 22 Battery Street, Suite 333 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for Plaintiff SEMHAL SIRAJ

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SEMHAL SIRAJ, Plaintiff, vs. BAYER HEALTHCARE LLC and DOES 1 through 20, Defendants. Case No. 3:09-cv-00233-SI JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING SUMMARY JUDGMENT DEADLINES Complaint Filed: Trial Date: December 18, 2008 April 12, 2010

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DB2/21405884.2

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STIP. TO EXTEND SUMMARY JUDGMENT DEADLINES CASE NO. 3:09-cv-00233-SI

Case3:09-cv-00233-SI Document34

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Plaintiff Semhal Siraj ("Plaintiff") and Defendant Bayer HealthCare LLC ("Defendant"), collectively referred to as the "Parties," by and through their undersigned counsel, file this stipulation to extend the deadlines related to summary judgment motions: WHEREAS, Plaintiff filed her Complaint on December 18, 2008; WHEREAS, on May 6, 2009, the Court issued a Pretrial Preparation Order ordering dispositive motions to be filed by November 13, 2009; opposition papers to be filed by November 30, 2009; reply papers to be filed by December 7, 2009; and the hearing to be scheduled no later than December 18, 2009; WHEREAS, the Court's May 6, 2009 Order set trial for March 22, 2010, with the pretrial conference set for March 9, 2010; WHEREAS, on August 18, 2009, the Court continued the trial date to April 12, 2010, continued the date for the pre-trial conference to March 30, 2010, and did not continue the summary judgment deadlines; WHEREAS, on October 8, 2009, the Court ordered the Parties to participate in a settlement conference on January 7, 2010; WHEREAS, the Parties have stipulated to a continuance of the deadlines for the motions for summary judgment in order to complete discovery and engage in good faith settlement discussions prior to filing dispositive motions; WHEREAS, neither party has been or will be prejudiced by the continuation of these litigation deadlines; WHEREAS, the Parties' stipulation does not affect the trial date or date for pre-trial conference; THEREFORE, the Parties request that the Court approve the following litigation deadlines:

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STIP. TO EXTEND SUMMARY JUDGMENT DEADLINES CASE NO. 3:09-cv-00233-SI

Case3:09-cv-00233-SI Document34

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Event Last day to file Notice of Motion for Summary Judgment: Last day to file Opposition to Motion for Summary Judgment

Old deadline 11/13/2009 11/30/2009 12/07/2009

New deadline 01/22/2010 02/05/2010 02/12/2010

4 Last day to file Reply to Opposition of Motion for Summary 5 Judgment 6 Hearing on Motion for Summary Judgment 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Dated: _______________ By The Honorable Susan Illston United States District Court Judge IT IS SO ORDERED. By /s/Michelle A. Griffith-Jones Michelle A. Griffith-Jones Attorneys for Defendant BAYER HEALTHCARE LLC Dated: November 5, 2009 By /s/James Achermann Jim Achermann Attorneys for Plaintiff SEMHAL SIRAJ MORGAN, LEWIS & BOCKIUS LLP IT IS SO STIPULATED. Dated: November 5, 2009 LAW OFFICES OF NEVIN & ABSALOM 12/18/2009 02/26/2010

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STIP. TO EXTEND SUMMARY JUDGMENT DEADLINES CASE NO. 3:09-cv-00233-SI