Filed: Feb. 26, 2019
Latest Update: Feb. 26, 2019
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSE TO SECOND AMENDED COMPLAINT HAYWOOD S. GILLIAM, JR. , District Judge . Pursuant to Local Rule 6-2, Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order extending Defendant's time to file its response to Plaintiff's Second Amended Complaint (Dkt. # 32, "Motion to Dismiss") until March 4, 2019. Good cause exists for the extension,
Summary: STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSE TO SECOND AMENDED COMPLAINT HAYWOOD S. GILLIAM, JR. , District Judge . Pursuant to Local Rule 6-2, Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order extending Defendant's time to file its response to Plaintiff's Second Amended Complaint (Dkt. # 32, "Motion to Dismiss") until March 4, 2019. Good cause exists for the extension, ..
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STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSE TO SECOND AMENDED COMPLAINT
HAYWOOD S. GILLIAM, JR., District Judge.
Pursuant to Local Rule 6-2, Plaintiff Beatrice Parker ("Plaintiff") and Defendant Cherne Contracting Corporation ("Defendant") hereby stipulate to this request that the Court enter an order extending Defendant's time to file its response to Plaintiff's Second Amended Complaint (Dkt. # 32, "Motion to Dismiss") until March 4, 2019. Good cause exists for the extension, and this extension should not affect the currently scheduled hearing date.
RECITALS
1. Defendant removed this case to the U.S. District Court for the Northern District of California on March 28, 2018. (Dkt. # 1.) Defendant subsequently filed its Motion to Dismiss (Dkt. No. 8).
2. On January 29, 2019, the Court granted in part and denied in part Defendant's Motion to Dismiss. (Dkt. No. 32.)
3. On February 11, 2019, Plaintiff filed a Second Amended Complaint (Dkt. No. 32 "SAC".)
4. Defendant's response to the SAC is currently due on February 25, 2019.
5. On February 22, 2019, the parties met and conferred and agreed to request an order extending the time for Defendant to file its response to Plaintiff's SAC. The parties agreed to an extension until March 4, 2019.
6. Good cause exists for the extension, and the extension request is brought in good faith and not for purposes of undue delay. Defendant is analyzing whether it will file a partial or complete motion to dismiss the SAC and is conferring with Plaintiff's counsel about the arguments.
STIPULATION
Pursuant to Local Civil Rule 6-2, the parties hereby jointly stipulate to a request for an order granting Defendant a seven-day extension, until March 4, 2019, within which to file its response to Plaintiff's Second Amended Complaint.
Signature Attestation
Pursuant to Local Rule 5-1(i)(3), I attest that concurrence in the filing of this document has been obtained from each of the above signatories.
Dated: February 25, 2019 BAKER & McKENZIE LLP
By: /s/Arthur J. Rooney
Arthur J. Rooney
ORDER
Pursuant to the foregoing stipulation to extend time for Defendant to file its response to Plaintiff's Second Amended Complaint, Defendant's response is now due on March 4, 2019.
IT IS SO ORDERED.
