Chadam et al v. Palo Alto Unified School District

Filing 13

ORDER by Judge Claudia Wilken Granting 12 Stipulation TO EXTEND TIME FOR PLAINTIFFS TO FILE THEIR RESPONSE TO DEFENDANTS MOTION TO DISMISS (ndr, COURT STAFF) (Filed on 10/25/2013)

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1 2 3 4 5 6 7 8 9 10 11 12 Stephen R. Jaffe, Cal. Bar No. 49539 stephen.r.jaffe@jaffetriallaw.com Bailey K. Bifoss, Cal. Bar No. 278392 bailey.k.bifoss@jaffetriallaw.com THE JAFFE LAW FIRM 150 California Street, 21st Floor San Francisco, California 94111 T: (415) 618-0100 F: (415) 618-0080 Attorneys for Plaintiffs JAMES CHADAM And JENNIFER CHADAM Rodney L. Levin, Cal. Bar No. 169360 Eliza J. McArthur, Cal. Bar No. 152312 Jeffery W. Maisen, Cal. Bar No. 271809 MCARTHUR & LEVIN, LLP 637 N. Santa Cruz Avenue Los Gatos, California 95030 T: (408) 741-2377 F: (408) 741-2378 Attorneys for Defendant PALO ALTO UNIFIED SCHOOL DISTRICT 13 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 17 18 19 20 JAMES CHADAM and JENNIFER CHADAM, individually and on behalf of their minor children A.C. AND C.C., Plaintiffs, Case No.: C 13-04129 CW STIPULATION TO EXTEND TIME FOR PLAINTIFFS TO FILE THEIR RESPONSE TO DEFENDANT’S MOTION TO DISMISS; [PROPOSED] ORDER v. 21 22 23 24 PALO ALTO UNIFIED SCHOOL DISTRICT, a governmental entity created and existing under the laws of the State of California, Defendants. 25 26 27 28 STIPULATION AND [PROPOSED] ORDER C 13-04129 CW 1 2 Plaintiffs and Defendant hereby stipulate and agree as follows: 1. On October 11, 2013, Defendant filed a Motion to Dismiss Plaintiffs’ Complaint pursuant to 3 Fed. R. Civ. P. 12(b)(1) and 12(b)(6). Plaintiffs’ response to Defendant’s Motion to Dismiss is 4 currently due by October 25, 2013. 5 6 7 8 9 10 11 12 13 2. The Parties are now engaged in settlement discussions and require additional time to complete those discussions. 3. The Parties believe that the relief jointly requested will not prejudice the Court, either party, or their counsel. 4. No other time modifications have been requested regarding this pleading. 5. The Parties have agreed that Plaintiffs may have an extension of time, up to and including November 11, 2013, by which to respond to Defendant’s Motion to Dismiss. 6. The Parties agree that Defendant’s reply in support of its Motion to Dismiss, if any, will be filed not later than November 18, 2013. 14 15 Dated: October 24, 2013 THE JAFFE LAW FIRM 16 17 By: _______________/s/_____________ 18 Stephen R. Jaffe (SBN 49539) Bailey K. Bifoss (SBN 278392) 19 Attorneys for Plaintiffs 20 21 Dated: October 24, 2013 MCARTHUR & LEVIN, LLP 22 23 By: _______________/s/_____________ 24 25 Rodney L. Levin (SBN 169360) Eliza J. McArthur (SBN 152312) 26 Attorneys for Defendant 27 28 1 STIPULATION AND [PROPOSED] ORDER C 13-04129 CW 1 2 3 4 [PROPOSED] ORDER Based on the Parties’ stipulation and for good cause shown, IT IS HEREBY ORDERED as follows: The Court will GRANT the Parties an amended briefing schedule for the hearing on 5 Defendant’s Motion to Dismiss. Opposition papers, if any, shall be filed not later than November 11, 6 2013. Reply papers, if any, shall be filed not later than November 18, 2013. 7 8 9 IT IS SO ORDERED. 10 11 Date: 10/25/2013 ____________________________ 12 The Honorable Judge Claudia Wilken 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 STIPULATION AND [PROPOSED] ORDER C 13-04129 CW 1 2 ATTESTATION PURSUANT TO GENERAL ORDER NO. 45: Pursuant to General Order No. 45 of the Northern District of California, I attest that 3 concurrence in the filing of this document has been obtained from the other signatory to this 4 document. 5 6 7 Dated: October 24, 2013 THE JAFFE LAW FIRM 8 9 By: _______________/s/_____________ 10 11 Stephen R. Jaffe (SBN 49539) Bailey K. Bifoss (SBN 278392) 12 Attorneys for Plaintiffs 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1 STIPULATION AND [PROPOSED] ORDER C 13-04129 CW

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