Couto v. SABIC Innovative Plastics Salary Continuance Plan

Filing 24

STIPULATION AND ORDER 23 to Extend Time to Respond to First Amended Complaint. Signed by Judge Ronald M. Whyte on 3/21/13. (jgS, COURT STAFF) (Filed on 3/21/2013)

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1 2 3 4 5 6 7 8 9 10 11 12 13 Eric P. Mathisen, IN State Bar No. 19475-71 (Pro Hac Vice) eric.mathisen@ogletreedeakins.com Christopher M. Ahearn, Cal. Bar No. 239089 chris.ahearn@ogletreedeakins.com, OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Steuart Tower, Suite 1300 One Market Plaza San Francisco, CA 94105 Telephone: 415.442.4810 Facsimile: 415.442.4870 Attorneys for Defendants SABIC INNOVATIVE PLASTICS SALARY CONTINUANCE PLAN and SABIC INNOVATIVE PLASTICS, INC. Jason Wolford, State Bar No. 194177 Jason@wolfordlegal.com WOLFORD LAW FIRM 101 Tunstead Avenue San Anselmo, CA 94960 T: 415-429-5529 F: 748524-4853 Attorney for Plaintiff LAURIE COUTO 14 UNITED STATES DISTRICT COURT 15 NORTHERN DISTRICT OF CALIFORNIA 16 (SAN JOSE DIVISION) 17 18 LAURIE COUTO, 19 20 Plaintiff, v. 21 SABIC INNOVATIVE PLASTICS SALARY CONTINUANCE PLAN, SABIC 22 INNOVATIVE PLASTICS, INC., and DOES ONE through TEN, inclusive 23 Defendants. 24 Case No. CV12-00633 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO RESPOND TO FIRST AMENDED COMPLAINT Complaint Filed: February 9, 2012 Trial Date: None Set Judge: Hon. Ronald M. Whyte 25 26 27 28 Joint Stip to Respond to FAC.doc Case No. CV12-00633 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT 1 Pursuant to Local Rule 6-2, this stipulation is made by and between plaintiff Laurie Couto 2 (“Plaintiff”) and Defendants SABIC Innovative Plastics Salary Continuance Plan (“the Plan”) and 3 SABIC Innovative Plastics, Inc. (“SABIC”) (collectively, “Defendants”) (collectively, including 4 Plaintiff, “the Parties”), by and through their respective counsel of record, with respect to the 5 following: 6 7 WHEREAS, on May 8, 2013, Plaintiff filed her First Amended Complaint (the “FAC”) against Defendants; 8 9 WHEREAS, pursuant to Rules 15(a)(3) and 6(d) of the Federal Rules of Civil Procedure, Defendants’ response to the FAC is due March 25, 2013; 10 WHEREAS, due to the temporary absence of SABIC personnel whose work is essential to 11 Defendants’ response to the FAC, Defendants have requested an extension of the time for their 12 response to the FAC, to April 5, 2013; 13 WHEREAS, Plaintiff has agreed to Defendants’ request for such an extension; 14 WHEREAS, at the most recent Case Management Conference, the Court ordered that the 15 First Amended Complaint should be filed and responded to prior to the currently-scheduled April 16 12, 2013 Case Management Conference; 17 WHEREAS, the Parties’ stipulated due date (April 5, 2013) will be the same as the due date 18 for the Parties’ Case Management Statement for the April 12, 2013 Case Management Conference; 19 WHERAS, pursuant to Local Rule 6-2(a)(2), the previous time modifications in this case 20 were: (1) Continuance of case management conference from August 24, 2012 to October 19, 2012 21 (see Document 12, filed August 14, 2012); and (2) Continuance of case management conference 22 from January 18, 2013 to February 8, 2013 (see Document 19, filed January 17, 2013). 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// Joint Stip to Respond to FAC.doc 1 Case No. CV12-00633 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT 1 THEREFORE THE PARTIES STIPULATE that Defendants’ time to respond to the FAC 2 should be extended to April 5, 2013. 3 IT IS SO STIPULATED. 4 5 DATED: March 20, 2013 6 OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 7 By: 8 9 /s/ Christopher M. Ahearn Eric P. Mathisen Christopher M. Ahearn Attorneys for Defendant SABIC INNOVATIVE PLASTICS SALARY CONTINUANCE PLAN 10 11 12 13 14 DATED: March 20, 2013 WOLFORD LAW FIRM 15 16 By: /s/ Jason Wolford Jason Wolford 17 18 Attorneys for Plaintiff LAURIE COUTO 19 20 21 22 23 24 25 26 27 28 Joint Stip to Respond to FAC.doc 2 Case No. CV12-00633 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT 1 2 [PROPOSED] ORDER Having considered the submission of the parties and, good cause showing, the stipulation to 3 extend time for Defendants to respond to the First Amended Complaint is GRANTED. Defendants 4 shall have until April 5, 2013 to respond to the First Amended Complaint. 5 6 IT IS SO ORDERED. 7 8 Ronald M. Whyte United States District Judge 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Joint Stip to Respond to FAC.doc 3 Case No. CV12-00633 STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT

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