Meakin v. California Field Ironworkers Pension Trust et al

Filing 29

ORDER GRANTING 28 STIPULATION TO EXTEND DEADLINE. Signed by Judge Edward J. Davila on 11/16/2017. (ejdlc2S, COURT STAFF) (Filed on 11/16/2017)

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George M. Kraw (California Bar No. 71551)
Katherine McDonough (California Bar No. 241426)
Michael Bedolla (California Bar No. 302517)
KRAW LAW GROUP, APC
605 Ellis Street, Suite 200
Mountain View, California 94043
Telephone: [phone]
Facsimile: 650-314-7899
[e-mail]
[e-mail]
[e-mail]
Counsel for Defendants:
California Ironworkers Field
Pension Trust, and Board of Trustees of the
California Ironworkers Field Pension Trust
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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Case No.: 5:16-cv-07195-EJD

ROBERT MEAKIN,
Plaintiff,

JOINT STIPULATION AND
[PROPOSED] ORDER TO EXTEND
v.
TIME FOR DEFENDANTS TO FILE
REPLY/OPPOSITION TO PLAINTIFF’S
CALIFORNIA IRONWORKERS FIELD
CROSS-MOTION FOR SUMMARY
PENSION TRUST, and BOARD OF TRUSTEES JUDGMENT AND PLAINTIFF’S
OF THE CALIFORNIA IRONWORKERS
OPPOSITION TO DEFENDANTS
FIELD PENSION TRUST,
SUMMARY JUDGMENT MOTION
Defendants.

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Pursuant to Local Rule 6-2 of the Northern District of California, Defendants California

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Ironworkers Field Pension Trust and Board of Trustees of the California Ironworkers Field

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Pension Trust (“Defendants”) and Plaintiff, Robert Meakin (“Plaintiff”), by and through their

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attorneys of record, hereby stipulate to extend the Deadline for Defendants to file a combined

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Reply/Opposition to Plaintiff’s Cross-Motion for Summary Judgment and Plaintiff’s Opposition
JOINT STIPULATION TO EXTEND DEADLINE
Case No.: 5:16-cv-07195-EJD

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to Defendants Motion for Summary Judgment from November 20, 2017 to November 22, 2017.

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WHEREAS, the Standing Orders for Judge Edward J. Davila requires any opposition to a

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Cross-Motion to be incorporated into the Reply to the Opposition to the original like motion and

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be filed and served not more than 7 days after the filing of the combined Reply/Opposition.

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WHEREAS, the Plaintiff’s filed their Opposition to Defendants Summary Judgment

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Motion and a Cross-Motion for Summary Judgment on November 13, 2017 and November 14,

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2017 (ECF Nos. 26 and 27).

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WHEREAS, Defendants’ counsel Michael Bedolla is out of the office on his honeymoon
until November 27, 2017.
WHEREAS, Defendants’ other counsel, Katherine McDonough will be out of the office
attending all day meetings for clients on November 15, 16, and 20, 2017.
WHEREAS, Civil Local Rule 6-2(a) of the Northern District of California states, “The

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parties may file a stipulation … requesting an order changing time that would affect the date of

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an event or deadline already fixed by Court order, or that would accelerate or extend time frames

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set in the Local Rules or in the Federal Rules…”

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NOW, THEREFORE, in consideration of the forgoing, the parties agree and hereby

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stipulate that the Defendants shall file the combined Reply/Opposition to Plaintiff’s Cross-

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Motion for Summary Judgment and Plaintiff’s Opposition to Defendants Motion for Summary

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Judgment no later than Wednesday, November 22, 2017.

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IT IS SO STIPULATED.

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DATED: November 15, 2017

BOLT KEENLEY KIM LLP

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/s/ James P. Keenley
James P. Keenley (State Bar No. 253106)
Brian H. Kim (State Bar No. 215492)
BOLT KEENLEY KIM LLP
1010 Grayson Street, Suite Three
Berkeley, California 94710

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JOINT STIPULATION TO EXTEND DEADLINE
Case No.: 5:16-cv-07195-EJD

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(Counsel for Plaintiff)

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DATED: November 15, 2017

KRAW LAW GROUP, APC

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/s/ Katherine McDonough
Katherine McDonough, CA Bar No. 241426
KRAW LAW GROUP, APC
605 Ellis Street, Suite 200
Mountain View, California 94043
Telephone: [phone]
Facsimile: 650-314-7899
[e-mail]
(Counsel for Defendants)

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. Defendants Reply/Opposition is

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due by November 22, 2017.

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DATED: November 16, 2017
DISTRICT JUDGE EDWARD J. DAVILA

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JOINT STIPULATION TO EXTEND DEADLINE
Case No.: 5:16-cv-07195-EJD

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ATTESTATION

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I, Katherine McDonough, attest that James P. Keenley, attorney for the Plaintiff, Robert

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Meakin, has read and approved the foregoing, JOINT STIPULATION AND [PROPOSED]

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ORDER TO EXTEND TIME FOR DEFENDANTS TO FILE REPLY/OPPOSITION TO

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PLAINTIFF’S CROSS-MOTION FOR SUMMARY JUDGMENT AND PLAINTIFF’S

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OPPOSITION TO DEFENDANTS SUMMARY JUDGMENT MOTION, and has consented to

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its filing in this action.
/S/ KATHERINE MCDONOUGH
KATHERINE MCDONOUGH, ESQ.

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JOINT STIPULATION TO EXTEND DEADLINE
Case No.: 5:16-cv-07195-EJD

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