Nahat v. Ballet San Jose, Inc. et al

Filing 23

ORDER by Judge Saundra Brown Armstrong Granting 22 Stipulation TO EXTEND TIME TO RESPOND TO MOTION TO REMAND STATE LAW CLAIMS. (ndr, COURT STAFF) (Filed on 9/19/2013)

1 COOPER, WHITE & COOPER LLP
CHRISTOPHER J. MEAD (SBN 115091)
[e-mail]
2
SCOTT M. McLEOD (SBN 242035)
[e-mail]
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201 California Street, 17th Floor
4 San Francisco, California 94111
Telephone:
[phone]
[phone]
5 Facsimile:
6 Attorneys for Defendant Ballet San Jose Silicon
Valley, Inc. (erroneously sued as Ballet San Jose,
7 Inc.)
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, OAKLAND DIVISION

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12 DENNIS NAHAT, an individual,
Plaintiff,

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vs.

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CASE NO. C 13-02896 SBA
STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO RESPOND TO
MOTION TO REMAND STATE LAW
CLAIMS

15 BALLET SAN JOSE, INC., a corporation, and
DOES ONE through TWENTY,
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Defendants.
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Judge:
Date:
Time:
Crtrm.:

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Trial Date: None Set

Hon. Saundra B. Armstrong
November 12, 2013
1:00 p.m.
1

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The parties, by and through counsel, stipulate as follows:
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1.

On September 11, 2013 Plaintiff Dennis Nahat filed a Motion to Remand State

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Law Claims For Lack of Jurisdiction and, in the Alternative, Be Remanded in the Court's Statutory
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Discretion ("Motion to Remand"), set to be heard November 12, 2013 at 1:00 p.m. in Courtroom 1
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before the Hon. Saundra B. Armstrong.
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2.

Defendant Ballet San Jose Silicon Valley, Inc. ("BSJ") was served on September

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11, 2013, and its response is currently due on September 25, 2013, and Plaintiff's reply is due
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October 2.
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3.

BSJ seeks an extension of the time to respond because lead counsel for BSJ is out

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COOPER, WHITE
& COOPER LLP
ATTORNEYS AT LAW
201 CALIFORNIA STREET
SAN FRANCISCO, CA 94111-5002

729176.1

C 13-02896 SBA
STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION TO REMAND STATE
LAW CLAIMS

1 of the country from September 8 through September 22.
4.

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There have been no prior extensions of time regarding this motion. Plaintiff

3 requested an extension of time to respond to Defendant's Motion to Dismiss. The parties
4 stipulated to that extension, which the Court ordered on July 19, 2013. (Docket #15.)
5.

5

The requested time modification will not have an effect on the schedule of the case

6 as the Motion to Remand is set for hearing on November 12, 2013.
6.

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Pursuant to Civil Local Rule 6-2, the parties hereby stipulate that BSJ's response

8 shall be due October 4, 2013 and any reply shall be due October 11, 2013.
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10 DATED: September 18, 2013

COOPER, WHITE & COOPER LLP

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By:

/s
Scott M. McLeod
Attorneys for Defendant Ballet San Jose
Silicon Valley, Inc. (erroneously sued as
Ballet San Jose, Inc.)

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17 DATED: September 18, 2013

KERR & WAGSTAFFE LLP

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By:

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James M. Wagstaffe
Attorneys for Plaintiff Dennis Nahat

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COOPER, WHITE
& COOPER LLP
ATTORNEYS AT LAW
201 CALIFORNIA STREET
SAN FRANCISCO, CA 94111-5002

729176.1

C 13-02896 SBA
2
STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION TO REMAND STATE
LAW CLAIMS

1

ORDER
Having reviewed the above stipulation submitted by the parties, and good cause appearing,

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3 the Court hereby orders the following:
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1.

The deadline for BSJ to respond to the Motion to Remand is October 4, 2013.

2.

The deadline for any reply is October 11, 2013.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: September ___, 2013
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Saundra B. Armstrong

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COOPER, WHITE
& COOPER LLP
ATTORNEYS AT LAW
201 CALIFORNIA STREET
SAN FRANCISCO, CA 94111-5002

729176.1

C 13-02896 SBA
3
STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION TO REMAND STATE
LAW CLAIMS