Sullivan v. Finn

Filing 65

ORDER re 64 STIPULATION - Reset Deadlines as to 62 MOTION to Amend/Correct.Response due by 11/28/2016. Reply due by 12/5/2016. Signed by Judge William H. Orrick on 11/16/2016. (jmdS, COURT STAFF) (Filed on 11/16/2016)

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PILLSBURY WINTHROP SHAW PITTMAN LLP
PHILIP S. WARDEN (SBN 54752)
[e-mail]
ANDREW D. LANPHERE (SBN 191479)
[e-mail]
JUDY J. BAO (SBN 305560)
[e-mail]
Four Embarcadero Center, 22nd Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
STEPHEN A. FINN
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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Case No. 16-cv-01948-WHO

JOANNA C. SULLIVAN
Plaintiff,
vs.
STEPHEN A. FINN and DOES 1 through 10,
inclusive

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Defendant.

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES
FOR RESPONSE AND REPLY TO
PLAINTIFF’S MOTION TO AMEND
PLAINTIFF’S COMPLAINT [DKT. 62]
Date:
December 14, 2016
Time:
2:00 p.m.
Judge:
Hon. William H. Orrick
Location Ctrm. 2, 17th Fl.

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Plaintiff Joanna C. Sullivan (“Plaintiff”) and Defendant Stephen A. Finn (“Defendant”)
(collectively, the “Parties”), in accord with Rules 6-1 and 6-2 of the Local Rules for the United
District Court for the Northern District of California, by and through their counsel of record,
stipulate and agree as follows:
WHEREAS, Plaintiff has filed a motion to amend Plaintiff’s complaint (“Motion to
Amend”) [Dkt. 62];

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-1STIPULATION TO EXTEND DEADLINES
FOR RESPONSE AND REPLY TO
PLAINTIFF’S MOT. TO AMEND COMPLAINT

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WHEREAS, Defendant’s Response to Plaintiff’s Motion to Amend filed on November 4,

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2016 [Dkt. 62] is currently due on November 18, 2016, and Plaintiff’s Reply to Defendant’s

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Response is currently due on November 25, 2016;

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WHEREAS, the Court has set the Motion to Amend hearing for December 14, 2016 [Dkt.
62];

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WHEREAS, the Parties have met and conferred about potentially resolving the Motion to
Amend without the need for further briefing or a hearing;

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WHEREAS, Defendant’s counsel has been unable to confer with client regarding the

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Motion to Amend due to Defendant’s need to attend to serious health issues in Defendant’s family;

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and

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WHEREAS, Plaintiff is willing to provide Defendant with additional time to respond to the

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Motion to Amend so that Defendant’s counsel can confer with Defendant and potentially resolve

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the Motion to Amend without the need for further briefing or a hearing.

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NOW THEREFORE, the Parties stipulate and agree, subject to the Court’s approval, as
follows:

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1.

2.

Plaintiff’s Reply to the Response to the Motion to Amend will due on December 5,

and

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Defendant’s Response to the Motion to Amend will be due on November 28, 2016;

2016.

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Respectfully submitted,
Dated: November 16, 2016.

PILLSBURY WINTHROP SHAW PITTMAN LLP
Philip S. Warden
Andrew D. Lanphere
Judy J. Bao
By: _/s/ Andrew D. Lanphere
Attorney for Defendant Stephen A. Finn

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-2–
STIPULATION TO EXTEND DEADLINES
FOR RESPONSE AND REPLY TO
PLAINTIFF’S MOT. TO AMEND COMPLAINT

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BEYERS COSTIN SIMON

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By: _/s/ Peter L. Simon_____________
Peter L. Simon
Attorney for Plaintiff Joanna C. Sullivan

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ATTESTATION CLAUSE
I attest under penalty of perjury that the concurrence in filing of this document has been
obtained from its signatories.

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By: _/s/ Andrew D. Lanphere___________

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-3–
STIPULATION TO EXTEND DEADLINES
FOR RESPONSE AND REPLY TO
PLAINTIFF’S MOT. TO AMEND COMPLAINT

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[PROPOSED] ORDER

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Based on the stipulation of the parties and good cause appearing therefor, it is hereby

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ORDERED that:

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1.

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Defendant’s Response to Plaintiff’s Motion to Amend Plaintiff’s Complaint

[Dkt. 62] shall be due on November 28, 2016; and
2.

Plaintiff’s Reply to Defendant’s Response to Plaintiff’s Motion to Amend Plaintiff’s

Complaint shall be due on December 5, 2016.

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IT IS SO ORDERED:

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November 16, 2016
Dated: __________________________

___________________________________

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William H. Orrick
United States District Judge

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