Hassani v. Siemens Medical Solutions USA

Filing 6

STIPULATION AND ORDER EXTENDING DEADLINE TO FILE RESPONSIVE PLEADING. Signed by Judge Jeremy Fogel on 8/15/05. (jfsec, COURT STAFF) (Filed on 8/15/2005)

Hassani v. Siemens Medical Solutions USA

Doc. 6

Case 5:05-cv-03083-JF

Document 6

Filed 08/15/2005

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13

RAYMOND L. WHEELER (BAR NO. 52886) SHARYN K. FUNAMURA (BAR NO. 193518) MORRISON & FOERSTER LLP 755 Page Mill Road Palo Alto, California 94304-1018 Telephone: [phone] Telefacsimile: [phone] Electronic Mail: [e-mail] [e-mail] Attorneys for Defendant SIEMENS MEDICAL SOLUTIONS USA, INC. (erroneously named and sued as Siemens Ultra Sound Corporation in State Court action)

**E-filed 8/15/05**

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION REZA HASSANI, No. Plaintiff, C05 03083 JF

14 15

v.
16 17 18 19 20 21 22 23 24 25 26 27 28

STIPULATION TO EXTEND DEFENDANT'S DEADLINE TO FILE RESPONSIVE PLEADING Honorable Jeremy Fogel Action Removed: July 29, 2005

SIEMENS MEDICAL SOLUTIONS USA, INC., and DOES 1-50, Inclusive, Defendants.

Plaintiff Reza Hassani ("Plaintiff") and Defendant Siemens Medical Solutions USA, Inc., ("Defendant") hereby stipulate to the following: RECITALS WHEREAS, Plaintiff filed his Complaint in Superior Court of California, County of Santa Clara on April 11, 2005, case number 1-05-CV-039062, which Complaint asserts three (3) causes of action for infliction of emotional distress, termination violative of public policy, and breach of an implied-in-fact contract; WHEREAS, Defendant was personally served with a copy of the Complaint on June 29, 2005;
STIPULATION TO CONTINUE DEFENDANT'S DEADLINE TO FILE RESPONSIVE PLEADING Case No. C05 03083 JF pa-999432

1

Dockets.Justia.com

Case 5:05-cv-03083-JF

Document 6

Filed 08/15/2005

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

WHEREAS, Defendant timely filed a Notice of Removal on July 29, 2005 and removed said action to this Court on the basis of diversity jurisdiction; WHEREAS, Defendant has not yet filed a responsive pleading in response to Plaintiff's Complaint; WHEREAS, the deadline for Defendant to file an answer or other responsive pleading to Plaintiff's Complaint is Friday, August 5, 2005; WHEREAS, the parties have agreed that the deadline for Defendant to file a responsive pleading to Plaintiff's Complaint shall be continued for fourteen (14) days, until Friday, August 19, 2005. STIPULATION IT IS HEREBY STIPULATED BY THE PARTIES, that the deadline for Defendant to file a responsive pleading in response to Plaintiff's Complaint shall be continued from Friday, August 5, 2005 until Friday, August 19, 2005. Pursuant to this stipulation, Defendant shall file and serve a responsive pleading on or before Friday, August 19, 2005. Dated: August 3, 2005 RAYMOND L. WHEELER SHARYN K. FUNAMURA MORRISON & FOERSTER LLP

s/Sharyn K. Funamura SHARYN K. FUNAMURA Attorneys for Defendant SIEMENS MEDICAL SOLUTIONS USA, INC. Dated: August 3, 2005 FRANK E. MAYO ATTORNEY AT LAW

s/Frank E. Mayo FRANK E. MAYO Attorney for Plaintiff REZA HASSANI

STIPULATION TO CONTINUE DEFENDANT'S DEADLINE TO FILE RESPONSIVE PLEADING Case No. C05 03083 JF pa-999432

2

Case 5:05-cv-03083-JF

Document 6

Filed 08/15/2005

Page 3 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

I, Sharyn K. Funamura, am the ECF User whose ID and password are being used to file this Stipulation to Continue Defendant's Deadline to File Responsive Pleading. In compliance with General Order 45, X.B., I hereby attest that Frank E. Mayo has concurred in this filing and that I have on file all holograph signatures for any signatures indicated by a "conformed" (s/) signature within this efiled document. Dated: August 3, 2005 RAYMOND L. WHEELER SHARYN K. FUNAMURA MORRISON & FOERSTER LLP

By:

s/ Sharyn K. Funamura Sharyn K. Funamura

Attorneys for Defendant SIEMENS MEDICAL SOLUTIONS USA, INC.

IT IS SO ORDERED. 8/15/05 /s/electronic signature authorized Judge Jeremy Fogel United States District Court

STIPULATION TO CONTINUE DEFENDANT'S DEADLINE TO FILE RESPONSIVE PLEADING Case No. C05 03083 JF pa-999432

3