Filed: Jan. 07, 2015
Latest Update: Jan. 07, 2015
Summary: STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER THEREON [LOCAL RULE 6-1] LUCY H. KOH, District Judge. STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT The parties to the above-captioned case, by and through their undersigned counsel of record, hereby respectfully request that Defendants Service Employees International Union, Local 521 (hereinafter "SEIU Local 521"), Alan Minato, 1 Controller-Treasurer of the County of Santa Clara (her
Summary: STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER THEREON [LOCAL RULE 6-1] LUCY H. KOH, District Judge. STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT The parties to the above-captioned case, by and through their undersigned counsel of record, hereby respectfully request that Defendants Service Employees International Union, Local 521 (hereinafter "SEIU Local 521"), Alan Minato, 1 Controller-Treasurer of the County of Santa Clara (here..
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STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER THEREON
[LOCAL RULE 6-1]
LUCY H. KOH, District Judge.
STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
The parties to the above-captioned case, by and through their undersigned counsel of record, hereby respectfully request that Defendants Service Employees International Union, Local 521 (hereinafter "SEIU Local 521"), Alan Minato,1Controller-Treasurer of the County of Santa Clara (hereinafter "Controller-Treasurer Minato"), and County of Santa Clara (hereinafter "County") be granted until and including February 6, 2015, to respond to Plaintiffs' Complaint. In support of that request, the parties state as follows:
1. The responsive pleading on behalf of Controller-Treasurer Minato is currently due January 16, 2015. The requested extension until and including February 6, 2015 will afford Controller-Treasurer Minato a twenty-one (21) day extension of time to respond to the Complaint.
2. The responsive pleading on behalf of the County is currently due January 12, 2015. The requested extension until and including February 6, 2015 will afford County a twenty-five (25) day extension of time to respond to the Complaint.
3. The responsive pleading on behalf of SEIU Local 521 is currently due on January 8, 2015. The requested extension until and including February 6, 2015 will afford Local 521 a twenty-eight (28) day extension of time to respond to the Complaint.
4. No previous extensions of time to respond to the Complaint have been requested or granted in this case.
5. The requested extension of time is necessary because Defendants have either only recently secured, or are currently in the process of securing, counsel to represent them in this case, Plaintiffs' Complaint contains numerous factual allegations that counsel must investigate in order to prepare responsive pleadings, and Defendants' counsel have a number of litigation commitments that will require their attention during the month of January.
6. The requested extension of time will not require the Court to reschedule any pretrial dates previously scheduled in this case.
The foregoing is hereby stipulated among the parties in this action, who respectfully request the Court to grant the extension of time. GARY, TILL & BURLINGHAM
[PROPOSED] ORDER
IT IS SO ORDERED.
