Young America's Foundation et al v. Napolitano et al

Filing 31

ORDER CONTINUING PLAINTIFFS' DEADLINE TO FILE FIRST AMENDED COMPLAINT; SETTING BRIEFING AND HEARING SCHEDULE; CONTINUING CASE MANAGEMENT CONFERENCE. Signed by Judge Maxine M. Chesney on 10/27/2017. (mmclc2, COURT STAFF) (Filed on 10/27/2017)

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HARMEET K. DHILLON (SBN: 207873)
[e-mail]
KRISTA L. BAUGHMAN (SBN: 264600)
[e-mail]
GREGORY R. MICHAEL (SBN: 306814)
[e-mail]
DHILLON LAW GROUP INC.
177 Post Street, Suite 700
San Francisco, California 94108
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs Young America’s Foundation
and Berkeley College Republicans

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION
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YOUNG AMERICA’S FOUNDATION, et al.,

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Plaintiffs,

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v.

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JANET NAPOLITANO, et al.,

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Defendants.

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Case Number: 3:17-cv-02255-MMC
Honorable Judge Maxine M. Chesney
STIPULATION AND [PROPOSED]
ORDER CONTINUING PLAINTIFFS’
DEADLINE TO FILE FIRST
AMENDED COMPLAINT; SETTING
BRIEFING AND HEARING
SCHEDULE; AND CONTINUING
CASE MANAGEMENT
CONFERENCE
Action Filed: April 24, 2017
Trial Date: Not Assigned

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36847276.1

Stipulation and [PROPOSED] Order Continuing
Briefing Deadlines, Motion Hearing, and CMC

Case No. 3:17-cv-02255-MMC

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STIPULATION AND [PROPOSED] ORDER

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In support of this Stipulation, the Parties stipulate and agree as follows:

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WHEREAS, on April 24, 2017, Plaintiffs filed the Complaint against Defendants;

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WHEREAS, on September 29, 2017, the Court held a hearing on Defendants’ motion to

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dismiss the Complaint, and granted the motion with leave to amend the Complaint (See Dkt. #27);
WHEREAS, the Court ordered that Plaintiffs shall file a First Amended Complaint (“FAC”) no

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later than October 27, 2017, and scheduled the Initial Case Management Conference for January 19,

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2018 (Dkt. #25, 27);

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WHEREAS, the Parties anticipate that Defendants will file a motion to dismiss the FAC;
WHEREAS, the Thanksgiving Day, Christmas Day, and New Year’s Day Court holidays fall
during the default briefing and hearing schedule for the anticipated motion;
WHEREAS, counsel for Defendants has a previously scheduled arbitration hearing from
March 19, 2017 through March 23, 2017;
WHEREAS, the following time modifications have been made in the case, whether by
stipulation or Court order:


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times, and is currently set for January 19, 2018 (Dkt. #15, 17, 25);


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

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Defendants’ deadline to file a reply in support of the motion to dismiss was continued from
July 19, 2017 to August 25, 2017 (Dkt. #17);



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Plaintiffs’ deadline to file an opposition to Defendants’ motion to dismiss the Complaint
was continued from July 12, 2017 to August 11, 2017 (Dkt. #17);

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Defendants’ deadline to respond to the Complaint was continued from May 18, 2017 to
June 28, 2017 (Dkt. #17);

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the initial Case Management Conference has been continued from July 28, 2017 three

the hearing on Defendants’ motion to dismiss was continued from August 25, 2017 to
September 29, 2017 (Dkt. #17);

WHEREAS, the Parties stipulate and respectfully request that the Court: continue Plaintiffs’

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deadline to file the FAC by two weeks, to November 10, 2017; set the below briefing schedule for

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Defendants’ anticipated motion to dismiss the FAC; and continue the Initial Case Management

36847276.1

Stipulation and [PROPOSED] Order Continuing
Briefing Deadlines, Motion Hearing, and CMC

1
Case No. 3:17-cv-02255-MMC

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Conference and corresponding deadlines, as set forth below;
WHEREAS, the Parties do not believe the requested continuance will have any effect on the
overall schedule for this case;
NOW THEREFORE, in light of the intervening holidays and trial schedule for counsel, the
Parties stipulate and respectfully request that the following schedule govern the case:

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DATE

EVENT

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November 10, 2017

Plaintiffs’ deadline to file First Amended Complaint

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December 8, 2017

Defendants’ deadline to file Motion to Dismiss

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January 12, 2018

Plaintiffs’ deadline to file response to Motion to Dismiss

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January 26, 2018

Defendants’ deadline to file reply to Plaintiffs’ response

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February 9, 2018

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March 9, 2018

Hearing on Motion to Dismiss at 9:00 a.m.
Last day to meet and confer regarding Rule 26 initial disclosures,
early settlement, ADR process selection, and discovery plan;

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File ADR Certification;

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March 23, 2018

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March 30, 2018

File either Stipulation to ADR Process or Notice of Need for ADR
Phone Conference
Last day to file Rule 26(f) report, complete initial disclosures or
state objection in Rule 26(f) report and file Case Management
Statement
Initial Case Management Conference at 10:30 a.m.

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Respectfully submitted,

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Dated: October 25, 2017

DHILLON LAW GROUP INC.

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By: /s/ Harmeet K. Dhillon
Harmeet K. Dhillon
Attorney for Plaintiffs

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36847276.1

Stipulation and [PROPOSED] Order Continuing
Briefing Deadlines, Motion Hearing, and CMC

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Case No. 3:17-cv-02255-MMC

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Dated: October 25, 2017

MUNGER, TOLLES & OLSON LLP

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By: /s/ Bryan Heckenlively
Bryan Heckenlively
Attorney for Defendants

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DECLARATION
Pursuant to Local Rule 6-2, I declare under penalty of perjury under the laws of the United
States that the foregoing is true and correct.

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Dated: October 25, 2017

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DHILLON LAW GROUP INC.
By: /s/ Harmeet K. Dhillon
Harmeet K. Dhillon
Attorney for Plaintiffs

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ATTESTATION PURSUANT TO CIVIL L.R. 5-1(i)(3)

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I, Harmeet K. Dhillon, am the ECF User whose ID and password are being used to file this

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document. I hereby attest that concurrence in the filing of this document has been obtained from the

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signatories.

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Dated: October 25, 2017

DHILLON LAW GROUP INC.
By: /s/ Harmeet K. Dhillon
Harmeet K. Dhillon

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36847276.1

Stipulation and [PROPOSED] Order Continuing
Briefing Deadlines, Motion Hearing, and CMC

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Case No. 3:17-cv-02255-MMC

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. with the exception that the hearing on
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any motion to dismiss will be held on February 16, 2018.

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DATED: ________________, 2017
October 27

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Honorable Maxine M. Chesney
United States District Judge

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36847276.1

Stipulation and [PROPOSED] Order Continuing
Briefing Deadlines, Motion Hearing, and CMC

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Case No. 3:17-cv-02255-MMC