International Longshore and Warehouse Union v. Solis et al

Filing 19

ORDER granting re 18 Stipulation To Enlarge Time To Respond to Plaintiff's Motion For Preliminary Injunction filed by Raymond M. Jefferson, Hilda Solis, U.S. Department of Labor. Signed by Judge Susan Illston on 6/2/11. (fj, COURT STAFF) (Filed on 6/2/2011)

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TONY WEST
Assistant Attorney General
Civil Division
JUDRY L. SUBAR
Assistant Branch Director
Federal Programs Branch
VIKAS DESAI (NY Bar)
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W.
Washington, DC 20530
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants Hilda Solis,
Secretary of Labor; Raymond M.
Jefferson, Assistant Secretary for
Veterans Employment and Training;
and U.S. Department of Labor

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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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INTERNATIONAL LONGSHORE AND
WAREHOUSE UNION,

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Plaintiff,
v.
HILDA SOLIS, Secretary of Labor;
RAYMOND M. JEFFERSON, Assistant
Secretary for Veterans Employment and
Training; and U.S. DEPARTMENT OF
LABOR,
Defendants.

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Case No. 3:11-cv-01939 (SI)
ORDER
JOINT STIPULATION TO ENLARGE
TIME TO RESPOND TO PLAINTIFF’S
MOTION FOR PRELIMINARY
INJUNCTION

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On May 26, 2011 Plaintiff made a filing with this Court in which it moved for a
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preliminary injunction. In that filing, Plaintiff noticed a hearing date for that motion of July 1,
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Joint Stipulation to Enlarge Defendants’ Time to Respond to Plaintiff’s Motion for Preliminary Injunction
3:11-cv-01939 (SI)

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2011. Pursuant to Local Civil Rule 7-3(a), Defendants’ response to this motion must be filed by

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Friday, June 10, 2011, and pursuant to Local Civil Rule 7-3(c), Plaintiff’s Reply must be filed by

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Friday, June 17, 2011. The parties hereby file a stipulation requesting (1) that the due date for

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Defendants to file their response be changed to Tuesday, June 14, 2011 and (2) that the due date

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for Plaintiff to file its Reply be changed to Tuesday, June 21, 2011. As required by Local Civil

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Rule 6-2(a), the parties declare the following:

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(1)

The reason for the requested enlargement of time is the unavailability of

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Defendants’ counsel on the days leading up to the date on which the filing is

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currently due. This case is being litigated on behalf of Defendants by attorneys at

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the U.S. Department of Justice. The attorney with primary supervisory

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responsibility over litigation of this case at the Department of Justice will be

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absent from work for much of the week of June 6-10, 2011, and will therefore be

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unable to work on this case. The primary attorney at the Department of Labor

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responsible for assisting Department of Justice attorneys with this matter is also

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unavailable for much of that week due to preexisting commitments on other

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matters. Defendants ability to adequately respond to Plaintiff’s Motion for

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Preliminary Injunction will be compromised without the contributions of these

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two attorneys.

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(2)

There have been no previous time modifications in this case.

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(3)

Under the current schedule of this case, any Reply by Plaintiff in support of its

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motion would be due by June 17, 2011. So as not to reduce the amount of time

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Plaintiff would be afforded to compose this filing, the parties request that the due

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date of Plaintiff’s Reply be changed to June 21, 2011. The parties request that the

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hearing date remain set for July 1, 2011.

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Joint Stipulation to Enlarge Defendants’ Time to Respond to Plaintiff’s Motion for Preliminary Injunction
3:11-cv-01939 (SI)

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Dated: May 31, 2011

Respectfully submitted,
TONY WEST
Assistant Attorney General
Civil Division

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/s/ Eleanor Morton
ROBERT S. REMAR (SBN 100124)
ELEANOR MORTON (SBN 220407)
NICHOLAS WELLINGTON (SBN 226954)
LEONARD CARDER, LLP
1188 Franklin Street, Suite 201
San Francisco, CA 94109
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Plaintiff

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JUDRY L. SUBAR
Assistant Branch Director
Federal Programs Branch

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/s/ Vikas Desai
VIKAS DESAI (NY Bar)
Trial Attorney
United States Department of Justice
Civil Division, Federal Programs Branch
20 Massachusetts Avenue, N.W. Rm 7206
Washington, DC 20530
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendants

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UNIT
ED

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DATED: June 2, 2011

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Joint Stipulation to Enlarge Defendants’ Time to Respond to Plaintiff’s Motion for Preliminary Injunction
3:11-cv-01939 (SI)

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