Filed: Oct. 07, 2015
Latest Update: Oct. 07, 2015
Summary: STIPULATION AND [PROPOSED] ORDER RE SCHEDULE (AS MODIFIED BY THE COURT) KANDIS A. WESTMORE , District Judge . STIPULATION WHEREAS, Assistant United States Attorney Michelle Lo has been the lead defense lawyer on this matter and has handled all aspects of the day-to-day litigation; WHEREAS, AUSA Lo went into an earlier-than-anticipated labor and gave birth to her first child on Saturday, October 3, 2015; WHEREAS, AUSA Lo had hoped to file defendant's summary judgment motion, currently due
Summary: STIPULATION AND [PROPOSED] ORDER RE SCHEDULE (AS MODIFIED BY THE COURT) KANDIS A. WESTMORE , District Judge . STIPULATION WHEREAS, Assistant United States Attorney Michelle Lo has been the lead defense lawyer on this matter and has handled all aspects of the day-to-day litigation; WHEREAS, AUSA Lo went into an earlier-than-anticipated labor and gave birth to her first child on Saturday, October 3, 2015; WHEREAS, AUSA Lo had hoped to file defendant's summary judgment motion, currently due ..
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STIPULATION AND [PROPOSED] ORDER RE SCHEDULE (AS MODIFIED BY THE COURT)
KANDIS A. WESTMORE, District Judge.
STIPULATION
WHEREAS, Assistant United States Attorney Michelle Lo has been the lead defense lawyer on this matter and has handled all aspects of the day-to-day litigation;
WHEREAS, AUSA Lo went into an earlier-than-anticipated labor and gave birth to her first child on Saturday, October 3, 2015;
WHEREAS, AUSA Lo had hoped to file defendant's summary judgment motion, currently due on October 16, 2015, before going out on leave, but was unable to do so in light of her baby's early arrival;
WHEREAS, AUSA Lo will be out on maternity leave for a number of months, including through the January 25, 2016 trial scheduled herein;
WHEREAS, this matter has just been reassigned to Assistant United States Attorney Wendy M. Garbers, who is unfamiliar with the file and will need some additional time to get up to speed and to prepare defendant's summary judgment motion;
IT IS HEREBY STIPULATED, by the parties to the above-captioned action, by and through their respective counsel of record, that all operative deadlines in this matter be extended approximately 45 days (slightly modified due to the holidays). Subject to the Court's availability, the parties propose the following schedule:
Deadline Current Proposed
Defendant's Summary October 16, 2015 November 19, 2015
Judgment Motion Due
Plaintiff's Summary October 30, 2015 December 8, 2015
Judgment Opposition Due
Defendant's Summary November 6, 2015 December 23, 2015
Judgment Reply Due
February 4, 2016
Summary Judgment Hearing November 19, 2015 January 7, 2016
July 5, 2016
Pretrial Conference January 12, 2016 at 3:00 p.m. March 1, 2016 at 3:00 p.m.
July 25-29, 2016
Trial January 25-29, 2016 March 14-18, 2016
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.