Johnson v. Sky Chefs, Inc.

Filing 12

ORDER re 11 Stipulation, filed by Saundra Johnson. Signed by Judge Lucy H. Koh on 12/12/2011. (lhklc2, COURT STAFF) (Filed on 12/12/2011)

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Alan Harris (SBN 146079)
HARRIS & RUBLE
6424 Santa Monica Blvd.
Los Angeles, CA 90038
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff

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Rebecca M. Aragon (SBN 134496)
Littler Mendelson
2049 Century Park East, Ste. 500
Los Angeles, CA 90067-3107
Tel: [phone]
Fax: [phone]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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SAUNDRA JOHNSON,
individually, and on behalf of all
others similarly situated,
Plaintiff,

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v.
SKY CHEFS, INC., a Delaware
business entity, and DOE ONE
through and including DOE ONE
HUNDRED,

Case No: CV11-05619 LHK
Assigned to Hon. Lucy H. Koh
STIPULATION AND [PROPOSED]
ORDER CONTINUING THE
DEADLINES FOR PLAINTIFF’S
OPPOSITION TO SKY CHEFS, INC.’S
MOTION TO DISMISS THE FIRST
AMENDED COMPLAINT AND SKY
CHEFS, INC.’S REPLY IN SUPPORT
OF ITS MOTION TO DISMISS THE
FIRST AMENDED COMPLAINT

Defendants.

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STIP.TO CONTINUE THE DEADLINES FOR PL.’S OPP. TO DEF.’S MTN. TO DISMISS AND DEF.’S REPLY

Plaintiff Saundra Johnson ("Plaintiff') and Defendant Sky Chefs, Inc.

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("Defendant") (Plaintiff and Defendant collectively referred to as "the Parties"), by and

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through their respective counsel, hereby stipulate and agree as follows:
STIPULATION

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WHEREAS, on or about October 18, 2011, Plaintiff commenced a civil action in

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Santa Clara Superior Court on behalf of herself and others similarly situated, entitled

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Saundra Johnson v. Sky Chefs, Inc., bearing Case No. 111 CV211330;
WHEREAS, Defendant was served with the Complaint on or about October 20,

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2011, and the First Amended Complaint ("FAC") on November 15, 2011;

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WHEREAS, Defendant removed the state action to the above-captioned court on
November21,2011;

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WHEREAS, Defendant filed a FRCP 12(b)(6) Motion to Dismiss the FAC (the

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"Motion") on November 28, 2011, which is scheduled to be heard on March 8, 2012;
WHEREAS, pursuant to Civil Local Rule 7-3(a),the deadline for Plaintiff to file an

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Oppositon to Defendant's Motion is December 12, 2011;

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WHEREAS, pursuant to Civil Local Rule 7-3(c), the deadline for Defendant to file

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a Reply in Support of its FRCP 12(b)(6) Motion to Dismiss the FAC is December 19,

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2011;

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WHEREAS, as described in the accompanying Declaration of Alan Harris, the

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parties have met and conferred regarding Defendant's Motion and desire to continue the

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Opposition and Reply deadlines so that the Parties can engage in good faith settlement

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negotiations in an effort to resolve this matter expeditiously and without further

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unwarranted expense;

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Therefore, the Parties stipulate and agree that:
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Plaintiff will file and serve any Opposition to the Motion, supporting
memoranda and documents on or before January 9, 2011;

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Defendant will file and serve any Reply in support of the Motion,

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STIP.TO CONTINUE THE DEADLINES FOR PL.'S OPP. TO DEF.'S MTN. TO DISMISS AND DEF.'S REPLY

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supporting memoranda and documents on or before February 15,

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2011.

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IT IS SO STIPULATED.

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DATED: December 7, 2011

Is/_ _ _ _ _ _ _ _ _ __

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Alan Harris
Attorneys for Plaintiff

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HARRIS & RUBLE

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DATED: Decemberf, 2011

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: December 12, 2011

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HONORABLE LUCY H. KOH

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STIP.TO CONTINUE THE DEADLINES FOR PL.'S OPP. TO DEF. 'S MTN. TO DISMISS AND DEF. 'S REPLY