Ramos v. The GAP, Inc.

Filing 19

ORDER GRANTING 18 STIPULATION to Extend Opposition and Reply Deadlines Associated With Defendant's 16 Motion to Dismiss. Reset Deadlines as to 16 MOTION to Dismiss : Responses due by 3/1/2024. Replies due by 3/15/2024. Signed by Judge Haywood S. Gilliam, Jr. on 2/7/2024. (ndr, COURT STAFF) (Filed on 2/7/2024)

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MORGAN, LEWIS & BOCKIUS LLP
Joseph Duffy, Bar No. 241854
Megan A. Suehiro, Bar No. 316104
Brittany M. Johnson, Bar No. 328436
300 South Grand Avenue, 22nd Floor
Los Angeles, CA 90071
T: +1.213.612.2500
F: +1.213.612.2501
[e-mail]
[e-mail]
[e-mail]

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Counsel for Defendant

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BURSOR & FISHER, P.A.
L. Timothy Fisher, Bar No. 191626
1990 North California Blvd., Suite 940
Walnut Creek, CA 94596
T: +1.925.300.4455
F: +1.925.407.2700
[e-mail]

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Joseph I Marchese (pro hac vice forthcoming)
Alec M. Leslie (pro hac vice forthcoming)
1330 Avenue of the Americas
New York, NY 10019
T: +1.646.837.7150
F. +1.212.989.9163
[e-mail]
[e-mail]

GUCOVSCHI ROZENSHTEYN, PLLC.
Adrian Gucovschi (pro hac vice
forthcoming)
630 Fifth Avenue, Suite 2000
New York, NY 10111
T: +1.212.884.4230
F. +1.212.884.4230
[e-mail]
Counsel for Plaintiff

Counsel for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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EFREN RAMOS, individually and on behalf of
all other persons similarly situated,

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Plaintiff,
vs.
THE GAP, INC.
Defendant.

Case 4:23-cv-04715-HSG
Hon. Haywood S. Gilliam, Jr.
STIPULATION TO EXTEND
OPPOSITION AND REPLY
DEADLINES ASSOCIATED WITH
DEFENDANT’S MOTION TO
DISMISS; ORDER

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STIPULATION TO EXTEND OPPOSITION AND REPLY DEADLINES
ASSOCIATED WITH DEFENDANT’S MOTION TO DISMISS; ORDER
CASE 4:23-CV-04715-HSG

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Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Efren Ramos (“Plaintiff”) and

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Defendant The Gap, Inc. (“Defendant”) (collectively the “Parties”), by and through their

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undersigned counsel, hereby respectfully submit this joint stipulation to extend the opposition and

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reply deadlines associated with Defendant’s Motion to Dismiss Complaint (“Motion to Dismiss”)

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(ECF No. 16):

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WHEREAS, Plaintiff’s Complaint was filed on September 13, 2023;

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WHEREAS, through four stipulations filed on December 6, 2023, January 5, 2024,

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January 12, 2024 and January 23, 2024, respectively, Defendant’s deadline to respond to

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Plaintiff’s Complaint was extended until January 26, 2024;

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WHEREAS, Defendant filed its Motion to Dismiss on January 26, 2024 and set the
hearing on the Motion to Dismiss for April 4, 2024 at 2:00 p.m.;
WHEREAS, pursuant to Civil Local Rule 7-3, Plaintiff’s opposition to Defendant’s
Motion to Dismiss is currently due on February 9, 2024;
WHEREAS, due to existing litigation conflicts, Plaintiff requires additional time to
prepare and file his opposition to Defendant’s motion to dismiss;
WHEREAS, the parties have met and conferred and agreed to extend Plaintiff’s deadline

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to file his opposition to the Motion to Dismiss from February 9, 2024 to March 1, 2024, as well as

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extend Defendant’s resultant deadline to file its reply by one week, from March 8, 2024 to March

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15, 2024;

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WHEREAS, there have been no previous requests to extend the opposition and reply
deadlines;

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WHEREAS, with these extensions, the briefing would be complete twenty (20) days

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before the April 4, 2024 hearing on Defendant’s Motion to Dismiss, which is sufficient time

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before the hearing under the Civil Local Rules;

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WHEREAS, these extensions would not alter the date of any event or any deadline
already fixed by Court order;

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STIPULATION TO EXTEND OPPOSITION AND REPLY DEADLINES
ASSOCIATED WITH DEFENDANT’S MOTION TO DISMISS; ORDER
CASE 4:23-CV-04715-HSG

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NOW, THEREFORE, the Parties stipulate that Plaintiff’s opposition to Defendant’s

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Motion to Dismiss shall be due on March 1, 2024, and Defendant’s reply in support of its Motion

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to Dismiss shall be due on March 15, 2024.

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IT IS SO STIPULATED.

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Dated: February 6, 2024

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BURSOR & FISHER, P.A.
By

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/s/ L. Timothy Fisher
L. Timothy Fisher
Counsel for Plaintiff

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Dated: February 6, 2024

MORGAN, LEWIS & BOCKIUS LLP

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By /s/ Joseph Duffy
Joseph Duffy
Counsel for Defendant

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STIPULATION TO EXTEND OPPOSITION AND REPLY DEADLINES
ASSOCIATED WITH DEFENDANT’S MOTION TO DISMISS; ORDER
CASE 4:23-CV-04715-HSG

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FILER’S ATTESTATION
Pursuant to Local Rule 5-1(i)(3) regarding signatures, I attest that all other signatories

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listed, and on whose behalf this filing is submitted, concur in the document’s content, and have

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authorized the filing.

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Dated: February 6, 2024

BURSOR & FISHER, P.A.
By: /s/ L. Timothy Fisher
L. Timothy Fisher
Counsel for Plaintiff

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STIPULATION TO EXTEND OPPOSITION AND REPLY DEADLINES
ASSOCIATED WITH DEFENDANT’S MOTION TO DISMISS; ORDER
CASE 4:23-CV-04715-HSG

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ORDER
Having considered the Parties’ Stipulation to Extend Opposition and Reply Deadlines

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Associated with Defendant’s Motion to Dismiss, and good cause appearing, it is hereby

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ORDERED that:

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1.

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Plaintiff’s opposition to Defendant’s Motion to Dismiss shall be due on March 1,
2024.

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Defendant’s reply in support of its Motion to Dismiss shall be due on March 15,
2024.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: 2/7/2024

_______________________________
Hon. Haywood S. Gilliam, Jr.
United States District Judge

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STIPULATION TO EXTEND OPPOSITION AND REPLY DEADLINES
ASSOCIATED WITH DEFENDANT’S MOTION TO DISMISS; ORDER
CASE 4:23-CV-04715-HSG

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