Thompson v. APM Terminals Pacific, Ltd.

Filing 5

STIPULATION AND ORDER re 4 Stipulation filed by APM Terminals Pacific, Ltd.. Signed by Judge Edward M. Chen on 3/26/10. (bpfS, COURT STAFF) (Filed on 3/26/2010)

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1 MCGUIREWOODS LLP 2 3 4 5 6 7 9 10 11 12 13 Matthew C. Kane, Esq. (SBN 171829) Email: mkane@mcguirewoods.com Michelle R. Walker, Esq. (SBN 167375) Email: mwalker@mcguirewoods.com Sabrina A. Beldner, Esq. (SBN 221918) Email: sbeldner@mcguirewoods.com Sylvia J. Kim, Esq. (SBN 258363) Email: skim@mcguirewoods.com 1800 Century Park East, 8th Floor Los Angeles, California 90067 Telephone: (310) 315-8200 Facsimile: (310) 315-8210 APM TERMINALS PACIFIC LTD UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA BRYAN THOMPSON, individual, on State of California Labor and CASE NO. CV-10-677 EMC STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT [Nor t h er n Distr ict Local Rule 6-1] Complaint Filed: ORDER 8 Attorneys for Defendant 14 behalf of himself and on behalf of The 15 Workforce Development Agency as a Private Attorney General, 16 Plaintiff, 17 18 20 21 22 23 24 25 26 27 28 10892557.1 vs. 19 CALIFORNIA CORPORATION; and APM TERMINALS PACIFIC LTD, A DOES 1 through 10, inclusive, Defendants. February 17, 2010 STIPULATION TO EXTEND TIME TO FILE RESPONSIVE PLEADING 1 1 2 3 RECITALS WHEREAS, Plaintiff BRYAN THOMPSON ("Plaintiff") filed a Complaint 4 on February 17, 2010 in the United States District Court for the Northern District of 5 California against Defendant APM TERMINALS PACIFIC LTD ("Defendant"); 6 and 7 8 10 11 13 14 WHEREAS, Plaintiff served Defendant with a Summons and Complaint in 9 this action on February 24, 2010; and WHEREAS, based on the foregoing and pursuant to Fed. R. Civ. P. 81(c)(2), 12 Defendant's deadline to respond to Plaintiff's Complaint is March 16, 2010; and WHEREAS, the parties agree and are stipulating herein pursuant to Local 15 Rule 6-1 to a 21-day extension of time for Defendant to serve and file any 16 responsive pleadings, to and including April 6, 2010. 17 18 19 20 22 that: 23 24 25 26 27 28 10892557.1 STIPULATION NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by 21 and between Plaintiff and Defendant through their respective undersigned counsel STIPULATION TO EXTEND TIME TO FILE RESPONSIVE PLEADING 2 1 2 3 4 5 6 7 1. Defendant's time within which to answer or otherwise serve and file any responsive pleadings to Plaintiff's Complaint in this action shall be and hereby is extended by 21 days to and including April 6, 2010; and 2. By entering into this Stipulation, Defendant does not waive and expressly reserves all defenses and challenges to Plaintiff's action. LAW OFFICES OF MICHAEL TRACY By: 8 DATED: March 9, 2010 9 10 11 12 13 14 15 17 18 19 20 21 22 23 24 25 26 27 28 10892557.1 Michael L. Tracy, Esq. Megan Ross Hutchins, Esq. Attorneys for Plaintiff BRYAN THOMPSON 16 DATED: March 9, 2010 MCGUIREWOODS LLP By: /s/ Matthew C. Kane Matthew C. Kane, Esq. Michelle R. Walker, Esq. Sabrina A. Beldner, Esq. Sylvia J. Kim, Esq. Attorneys for Defendant APM TERMINALS PACIFIC LTD IT IS SO ORDERED E STIPULATION TO EXTEND TIME TO FILE RESPONSIVE PLEADING RN D OF A 3 C LI FO dwa Judge E hen rd M. C R NIA _________________ ERED O ORD Edward M. Chen IT IS S U.S. Magistrate Judge UNIT ED S S DISTRICT TE C TA RT U O NO RT H

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