Buster v. Mechanics Bank Supplemental Executive Retirement Plan et al

Filing 46

ORDER EXTENDING TIME TO CONDUCT COURT-ORDERED DEPOSITIONS OF PLAINTIFF STEVEN BUSTER AND DIANNE FELTON OF MECHANICS BANK by Hon. William Alsup granting #45 Stipulation.(whalc1, COURT STAFF) (Filed on 6/20/2016)

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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R. Bradford Huss (SBN 71303)
Dylan D. Rudolph (SBN 278707)
TRUCKER  HUSS
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
E-mail:
[e-mail]
[e-mail]
Joseph C. Faucher (SBN 137353)
TRUCKER  HUSS
A Professional Corporation
633 West 5th Street, 26th Floor
Los Angeles, CA 90071
Telephone:
[phone]
Facsimile:
[phone]
E-mail:
[e-mail]
Attorneys for Defendants
COMPENSATION COMMITTEE OF THE
BOARD OF DIRECTORS OF MECHANICS BANK;
MECHANICS BANK SUPPLEMENTAL
EXECUTIVE RETIREMENT PLAN,
MECHANICS BANK, a California Corporation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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STEVEN K. BUSTER,

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Plaintiff,

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vs.
COMPENSATION COMMITTEE OF THE
BOARD OF DIRECTORS OF MECHANICS
BANK; MECHANICS BANK
SUPPLEMENTAL EXECUTIVE
RETIREMENT PLAN, MECHANICS
BANK, a California Corporation,

Case No.: 3:16-cv-01146-WHA
STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO
CONDUCT COURT-ORDERED
DEPOSITIONS OF PLAINTIFF STEVEN
BUSTER AND DIANNE FELTON OF
MECHANICS BANK
[Filed concurrently with Declaration of
Joseph C. Faucher pursuant to L-R 6-2(a)]

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Defendants.

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Order re:
STIPULATION EXTENDING TIME TO CONDUCT THE COURT-ORDERED DEPOSITIONS OF PLAINTIFF
STEVEN BUSTER AND DIANNE FELTON; Case No. 3:16-cv-01146-WHA

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Defendants COMPENSATION COMMITTEE OF THE BOARD OF DIRECTORS OF

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MECHANICS BANK; MECHANICS BANK SUPPLEMENTAL EXECUTIVE RETIREMENT

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PLAN and MECHANICS BANK (collectively, “Defendants”) and Plaintiff Steven K. Buster

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(“Plaintiff”) (together hereafter the “Parties”) hereby stipulate and agree, by and through their

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respective counsel, to extend the time for the Parties to conduct the court-ordered depositions of

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Plaintiff Steven Buster and Dianne Felton of Mechanics Bank, to now take place on July 6, 2016.

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WHEREAS, on June 9, 2016, the Court ordered that one-hour depositions of Plaintiff

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Steven Buster and Dianne Felton shall be taken on or before June 30, 2016, and specifically to take

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place on June 27, 2016 at 9:00 a.m. at the offices of Plaintiff’s counsel, Louderback Law Group,

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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located at 44 Montgomery Street, Suite 2970, San Francisco, California 94104. (Docket #41.)

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WHEREAS, good cause exists to extend the time to take the depositions of Plaintiff Steven

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Buster and Dianne Felton by reason of the fact that Dianne Felton is largely unavailable during the

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entire month of June. To accommodate their respective schedules, and at the same time proceed

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with the depositions at the earliest possible date, the Parties have agreed to proceed with the one-

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hour depositions of Plaintiff Steven Buster and Dianne Felton on July 6, 2016 at 9:00 a.m. at the

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offices of Plaintiff’s counsel, Louderback Law Group, located at 44 Montgomery Street, Suite 2970,

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San Francisco, California 94104.

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The Parties have not requested any prior extensions of time to conduct the depositions of

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Plaintiff Steven Buster or Dianne Felton. Prior time modifications in this case, whether by

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stipulation or Court order, include: (1) Defendants previously obtained a thirty (30) day extension of

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time, from April 6, 2016 to May 6, 2016, to respond to the original Complaint in this matter, by

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stipulation; (2) the Court issued an Order Extending Deadlines for Response and Reply Papers re

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Defendants’ Motion to Dismiss on May 18, 2016 (Docket #28); and (3) the Court issued an Order

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Extending Time for Defendants to Respond to Plaintiff’s Amended Complaint on June 9, 2016

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(Docket #39). The proposed order extending the time to conduct said depositions to July 6, 2016

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will not alter the date of any event or any deadline already fixed by Court order in this matter. This

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Stipulation is made and entered into pursuant to Local Rules 6-1(b) and 6-2(a).

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Order re:
STIPULATION EXTENDING TIME TO CONDUCT THE COURT-ORDERED DEPOSITIONS OF PLAINTIFF
STEVEN BUSTER AND DIANNE FELTON; Case No. 3:16-cv-01146-WHA

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THE PARTIES THEREFORE AGREE AND STIPULATE AS FOLLOWS:

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The depositions of Plaintiff Steven K. Buster and Dianne Felton of Mechanics Bank will

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now take place on July 6, 2016 at 9:00 a.m. at the offices of Plaintiff’s counsel, Louderback Law

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Group, located at 44 Montgomery Street, Suite 2970, San Francisco, California 94104.

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DATED: June 16, 2016

TRUCKER  HUSS

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By: /s/Joseph C. Faucher
R. Bradford Huss
Joseph C. Faucher
Dylan D. Rudolph
Attorneys for Defendants
COMPENSATION COMMITTEE OF THE
BOARD OF DIRECTORS OF MECHANICS
BANK; MECHANICS BANK SUPPLEMENTAL
EXECUTIVE RETIREMENT PLAN,
MECHANICS BANK, a California Corporation

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Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

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DATED: June 16, 2016

LOUDERBACK LAW GROUP

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By: /s/Charles M. Louderback
Charles M. Louderback
Attorney for Plaintiff
STEVEN K. BUSTER

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I attest that I have obtained Mr. Louderback’s concurrence in the filing of this document.
DATED: June 16, 2016

/s/Joseph C. Faucher
Joseph C. Faucher

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
June 20

DATED: _____________, 2016

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HON. WILLIAM ALSUP
UNITED STATES DISTRICT COURT JUDGE

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Order re:
STIPULATION EXTENDING TIME TO CONDUCT THE COURT-ORDERED DEPOSITIONS OF PLAINTIFF
STEVEN BUSTER AND DIANNE FELTON; Case No. 3:16-cv-01146-WHA

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