Casanave v. C.R. Bard, Inc. et al

Filing 38

JOINT STIPULATION AND ORDER RE 36 TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION TO DISMISS. Signed by Judge Richard Seeborg on 3/20/12. (cl, COURT STAFF) (Filed on 3/20/2012)

IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA

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ANGELA CASANAVE,

CASE NO. 3:11-cv-05308-RS

Plaintiff,

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v.

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JOINT STIPULATION TO EXTEND
TIME FOR PLAINTIFF TO RESPOND
TO DEFENDANT’S MOTION TO
DISMISS

C.R. BARD, INC., DAVOL, INC.; and W.
L. GORE ASSOCIATES, INC.,

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Defendant.

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COME NOW Plaintiff Angela Casanave and Defendant W. L. Gore Associates, Inc.

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(“Gore”) and hereby jointly stipulate and agree that the time for Plaintiff to respond to Defendant

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Gore’s Motion to Dismiss shall be extended until and through March 30, 2012, with Defendant’s

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reply brief deadline extended until and through April 6, 2012.

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1.

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2012. Plaintiff has sent a proposed Second Amended Complaint to Defendant, which removes

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certain causes of action as well as additional facts. Plaintiff sent the proposed Second Amended

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Complaint to defense counsel on March 14. Defense counsel has agreed to present the proposed

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Second Amended Complaint to Defendant. However, unbeknownst to Plaintiff’s counsel,

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Defendant’s representatives are entirely unavailable until this week beginning on March 19.

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2.

Defendant filed its Motion to Dismiss Plaintiff’s First Amended Complaint on March 2,

The parties wish for Plaintiff’s time to respond to be extended so that Defendant may

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have more time to review Plaintiff’s proposed Second Amended Complaint and so that the

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parties will have adequate time to meet and confer on any of Defendant’s remaining concerns

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regarding Plaintiff’s pleadings. This extension will not affect the hearing date for Defendant’s

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Motion to Dismiss, currently scheduled for April 19, 2012. Neither party has previously
requested an extension of deadlines in this case.

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PURSUANT TO STIPULATION, IT IS SO ORDERED
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3/20/12
DATE: ___________

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UNITED STATES DISTRICT JUDGE

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