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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Stephen R. Jaffe, Cal. Bar No. 49539
[e-mail]
Bailey K. Bifoss, Cal. Bar No. 278392
[e-mail]
THE JAFFE LAW FIRM
150 California Street, 21st Floor
San Francisco, California 94111
T: [phone]
F: [phone]
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: [phone]
F: [phone]
Attorneys for Defendant
PALO ALTO UNIFIED SCHOOL DISTRICT

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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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.

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PALO ALTO UNIFIED SCHOOL DISTRICT, a
governmental entity created and existing under
the laws of the State of California,
Defendants.

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STIPULATION AND [PROPOSED] ORDER
C 13-04129 CW

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Plaintiffs and Defendant hereby stipulate and agree as follows:
1. On October 11, 2013, Defendant filed a Motion to Dismiss Plaintiffs’ Complaint pursuant to

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Fed. R. Civ. P. 12(b)(1) and 12(b)(6). Plaintiffs’ response to Defendant’s Motion to Dismiss is

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currently due by October 25, 2013.

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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.

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Dated: October 24, 2013

THE JAFFE LAW FIRM

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By: _______________/s/_____________

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Stephen R. Jaffe (SBN 49539)
Bailey K. Bifoss (SBN 278392)

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Attorneys for Plaintiffs

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Dated: October 24, 2013

MCARTHUR & LEVIN, LLP

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By: _______________/s/_____________

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Rodney L. Levin (SBN 169360)
Eliza J. McArthur (SBN 152312)

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Attorneys for Defendant

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STIPULATION AND [PROPOSED] ORDER
C 13-04129 CW

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[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

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Defendant’s Motion to Dismiss. Opposition papers, if any, shall be filed not later than November 11,

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2013. Reply papers, if any, shall be filed not later than November 18, 2013.

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IT IS SO ORDERED.

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Date: 10/25/2013

____________________________

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The Honorable Judge Claudia Wilken

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STIPULATION AND [PROPOSED] ORDER
C 13-04129 CW

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ATTESTATION PURSUANT TO GENERAL ORDER NO. 45:
Pursuant to General Order No. 45 of the Northern District of California, I attest that

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concurrence in the filing of this document has been obtained from the other signatory to this

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document.

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Dated: October 24, 2013

THE JAFFE LAW FIRM

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By: _______________/s/_____________

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Stephen R. Jaffe (SBN 49539)
Bailey K. Bifoss (SBN 278392)

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Attorneys for Plaintiffs

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STIPULATION AND [PROPOSED] ORDER
C 13-04129 CW