Ryan v. Sandia Corporation

Filing 18

ORDER granted 16 STIPULATION WITH PROPOSED ORDER REGARDING BRIEFING SCHEDULE OF DEFENDANT'S CONTINUED MOTION AND MOTION TO DISMISS filed by Evelyn Ryan.Deadlines as to 14 MOTION to Dismiss Pursuant to Fed. R. Civ. P. 1 2(b)(6), 16 STIPULATION WITH PROPOSED ORDER REGARDING BRIEFING SCHEDULE OF DEFENDANT'S CONTINUED MOTION AND MOTION TO DISMISS. Responses due by 10/7/2105. Replies due by 10/14/2015. Signed by Judge Charles R. Breyer on 9/25/2015. (beS, COURT STAFF) (Filed on 9/25/2015)

1 Jody I. LeWitter (SBN 124794)
Jean R. Krasilnikoff (SBN 280450)
2 SIEGEL LEWITTER MALKANI
1939 Harrison Street, Suite 307
3 Oakland, California 94612
Phone: [phone]
4 Fax: [phone]
[e-mail]
5 [e-mail]
6 Attorneys for Plaintiff EVELYN RYAN
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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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) Case No. 15-cv-04102-CRB
)
) STIPULATION AND ORDER
Plaintiff,
) REGARDING BRIEFING
v.
) SCHEDULE OF DEFENDANT’S
) CONTINUED MOTION AND MOTION
SANDIA CORPORATION d/b/a SANDIA
) TO DISMISS PURSUANT TO FRCP
NATIONAL LABORATORIES and DOES 1 ) 12(b)(6) AND LOCAL RULE 7-7(d)
through 10, inclusive,
)
)
Defendants.
) Complaint Filed:
July 15, 2015
) Trial Date:
None set
)
)
EVELYN RYAN,

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NOW come the Parties by and through their counsels and stipulate to the following

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briefing schedule regarding Defendant’s Motion to Dismiss, which was previously noticed for

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November 13, 2015 and is now noticed for December 11, 2015:

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Opposition by Plaintiff to be filed by October 7, 2015. (Opposition date set by the Court

23 for the hearing of November 13, 2015 was on September 30, 2015).
Siegel,
LeWitter &
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Reply by Defendant to be filed on October 14, 2015. (Reply date set by the court for the
Malkani
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1939 Harrison Street
Suite 307
Oakland, CA 94612
510-452-5000
510-452-5004 (fax)

original motion was October 7, 2015).

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The Parties stipulate that there is good cause for the extension of the time to file an

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opposition and reply by one week for the reasons, inter alia, that Plaintiff’s counsel has a motion

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for summary judgment due on September 30, 2015 in another case, and other work obligations
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STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE OF
DEFENDANTS’ CONTINUED MOTION AND MOTION TO DISMISS – Case No. 15-cv-04102-CRB

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which provide good cause for moving the date by one week, the same amount of time will still be

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provided to Defendant to file its reply, and the same amount of time will be provided to the Court

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to review the papers, as the hearing date has been changed from November 13, 2015 to December

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11, 2015.

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Respectfully submitted,
DATED: September 21, 2015

SIEGEL LEWITTER MALKANI

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By:

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Attorneys for Plaintiff

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/s/ Jody I. LeWitter
Jody I. LeWitter
Jean R. Krasilnikoff

DATED: September 21, 2015

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By:

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/s/ Danielle Ochs
Danielle Ochs
Rachel J. Moroski

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Attorneys for Plaintiff Defendant
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SIGNATURE ATTESTATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this

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document has been obtained from the other signatories.

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DATED: September 21, 2015

By: /s/ Jody I. LeWitter

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ORDER

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Siegel,
This matter having come before the Court upon the stipulation of the parties pursuant to
LeWitter &
24 Local Rule 7-7(d) and good cause having been provided, it is hereby ordered that the opposition
Malkani
25
1939 Harrison Street
Suite 307
Oakland, CA 94612
510-452-5000
510-452-5004 (fax)

by Plaintiff shall be filed by October 7, 2015, and Defendant’s Reply shall be filed by October 14,

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2015.

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Sept. 25, 2015
DATED: ____________________

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__________________________________
Hon. Charles R. Breyer

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STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE OF
DEFENDANTS’ CONTINUED MOTION AND MOTION TO DISMISS – Case No. 15-cv-04102-CRB