Guenther v. Lockheed Martin Corporation et al

Filing 36

STIPULATION AND ORDER Granting Request for Extension of Deadline to Complete ADR Session re 35 Stipulation. The deadline to complete the ADR session shall be continued until sixty (60) days after the Court issues a decision on Defendants'Motion to Dismiss. Signed by Judge Edward J. Davila on 12/8/2011. (ecg, COURT STAFF) (Filed on 12/8/2011)

1
2
3
4
5
6

R. Bradford Huss, No. 71303
Clarissa A. Kang, No. 210660
Michelle L. Schuller, No. 255787
TRUCKER  HUSS
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, CA 94111-3617
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
[e-mail]

7
8
9
10

Attorneys for Defendants
LOCKHEED MARTIN CORPORATION
and LOCKHEED MARTIN CORPORATION
SALARIED EMPLOYEE RETIREMENT PROGRAM
(Sued as Lockheed Martin Corporation
Retirement Plan for Certain Salaried Employees)

11
Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

UNITED STATES DISTRICT COURT
12
NORTHERN DISTRICT OF CALIFORNIA
13
CHARLES GUENTHER, an individual,

Case No. 5:11-CV-00380-EJD

14
Plaintiff,
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE DEADLINE TO
COMPLETE ADR SESSION

15
vs.
16
17
18

LOCKHEED MARTIN CORPORATION,
LOCKHEED MARTIN CORPORATION
RETIREMENT PLAN FOR CERTAIN
SALARIED EMPLOYEES, and DOES 1 through
30,

19
Defendants.
20
21

This Stipulation to Continue Deadline to Complete ADR Session is made and entered into

22

by and among Plaintiff Charles Guenther (the “Plaintiff”) and Defendants Lockheed Martin

23

Corporation and Lockheed Martin Corporation Salaried Employee Retirement Program

24

(collectively, “Defendants”).

25

The Court in its September 15, 2011 Order Selecting ADR Process (Doc. No. 31) set the

26

deadline for holding the ADR session 90 days from the date of its order, and thus, such deadline is

27

December 14, 2011. The Plaintiff and Defendants agree and believe that for purposes of efficiency

28

and conservation of party and judicial resources, it is in the interests of all parties to continue this
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO COMPLETE ADR SESSION;
Case No. 5:11-CV-00380-EJD
#1218322

1

1

ADR deadline until sixty (60) days after the Court issues a decision on Defendants’ Motion to

2

Dismiss (Docket No. 14), which was heard on September 16, 2011 and is now pending. No other

3

deadlines in the case would be affected.

4

WHEREFORE, the parties stipulate and agree as follows:
STIPULATION

5
6

Subject to the Court’s approval of this stipulation, the deadline to complete the ADR

7

session shall be continued until sixty (60) days after the Court issues a decision on Defendants’

8

Motion to Dismiss.

9
10

IT IS SO STIPULATED.
DATED: December 7, 2011

PIERCE & SHEARER, LLP

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

11
By: /s/Andrew F. Pierce
Andrew F. Pierce
Attorneys for Plaintiff
CHARLES GUENTHER

12
13
14
15

DATED: December 7, 2011

TRUCKER  HUSS

16
By: /s/Clarissa A. Kang
Clarissa A. Kang
Attorneys for Defendants
LOCKHEED MARTIN CORPORATION and
LOCKHEED MARTIN CORPORATION
SALARIED EMPLOYEE RETIREMENT
PROGRAM

17
18
19
20
21

I attest that I have obtained Mr. Pierce’s concurrence in the filing of this document.

22
DATED: December 7, 2011
23

/s/Clarissa A. Kang
Clarissa A. Kang

24
25
26
27
28

STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO COMPLETE ADR SESSION;
Case No. 5:11-CV-00380-EJD
#1218322

2

1
2
3

[PROPOSED] ORDER
PURSUANT TO THE PARTIES’ STIPULATION, IT IS SO ORDERED.
December 8
DATED: __________________, 2011

4

_________________________________________
Hon. Edward J. Davila
Judge of the United States District Court

5
6
7
8
9
10

Trucker  Huss
A Professional Corporation
One Embarcadero Center, 12th Floor
San Francisco, California 94111

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO COMPLETE ADR SESSION;
Case No. 5:11-CV-00380-EJD
#1218322

3