Judy Ditchey v. Mechanics Bank et al

Filing 39

STIPULATION AND ORDER REGARDING SUPPLEMENTAL BRIEFING SCHEDULE re: 22 30 : IT IS ORDERED that Defendants shall produce relevant documents, including Change in Control Agreements for other key executives by 1/15/2016; Plaintiff shall file her Supplemental Brief by 1/25/2016; Defendants shall file their Response by 2/8/2016; and Plaintiff shall file her Reply by 2/15/2016. Signed by Judge Jacqueline S. Corley on 1/14/2016. (afmS, COURT STAFF) (Filed on 1/14/2016)

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Daniel Feinberg - State Bar No. 135983
FEINBERG, JACKSON, WORTHMAN & WASOW LLP
383 4th Street, Suite 201
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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Attorneys for Plaintiff
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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO/OAKLAND DIVISION

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JUDY DITCHEY,

Case No. 15-cv-4103 JCS

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Plaintiff,

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v.

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MECHANICS BANK, MECHANICS
BANK CHANGE IN CONTROL PLAN,

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Defendants.
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Stipulation and [Proposed] Order Re:
Supplemental Briefing Schedule
CASE NO. 15-cv-4103 JCS

STIPULATION AND [PROPOSED]
ORDER RE SUPPLEMENTAL BRIEFING
SCHEDULE

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WHEREAS the January 7, 2016 Order Re: Plaintiff’s Motion for Partial Summary

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Judgment (ECF 30) (“MSJ Order”) orders Plaintiff and Defendants “to file supplemental briefing

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regarding the issue of whether the Plan at issue is governed by ERISA. In particular, Plaintiff

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shall supplement the record with evidence supporting her argument that five other key executives

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at the Bank have similar Change in Control Plans”;

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WHEREAS the MSJ Order directs the parties to “meet and confer, and by January 15,

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2016, . . . file . . . a stipulation regarding the briefing schedule for the supplemental summary

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judgment briefing”;

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WHEREAS the parties have met and conferred, and have agreed to a briefing schedule for
supplemental summary judgment briefing;
THEREFORE, the Parties hereby request that the Court enter the following schedule for

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supplemental briefing on Plaintiff’s Motion for Partial Summary Judgment (ECF 22): (1)

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Defendants produce relevant documents, including Change in Control Agreements for other key

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executives by January 15, 2016; (2) Plaintiff files her Supplemental Brief by January 25, 2016;

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(2) Defendants file their Response by February 8, 2016; and (3) Plaintiff files her Reply by

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February 15, 2016.

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Dated: January 13, 2016

Respectfully Submitted,

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FEINBERG, JACKSON, WORTHMAN &
WASOW LLP

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By:

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/s/ Daniel Feinberg
Daniel Feinberg
Daniel Feinberg
383 4th Street, Suite 201
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff

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Stipulation and [Proposed] Order Re:
Supplemental Briefing Schedule
CASE NO. 15-cv-4103JCS

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ARENA HOFFMAN LLP
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By:
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/s/ Ron Arena
Ron Arena
44 Montgomery St., Suite 3520
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendants
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SO ORDERED. Defendants shall produce relevant documents, including Change in Control
Agreements for other key executives by January 15, 2016; Plaintiff shall file her Supplemental

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Brief by January 25, 2016; Defendants shall file their Response by February 8, 2016; and Plaintiff
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shall file her Reply by February 15, 2016.
Dated: January __, 2016
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__________________________
U.S. Magistrate Judge

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Stipulation and [Proposed] Order Re:
Supplemental Briefing Schedule
CASE NO. 15-cv-4103JCS

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