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Young America's Foundation v. Napolitano, 3:17-cv-02255-MMC. (2017)

Court: District Court, N.D. California Number: infdco20171030h19 Visitors: 14
Filed: Oct. 27, 2017
Latest Update: Oct. 27, 2017
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFFS' DEADLINE TO FILE FIRST AMENDED COMPLAINT; SETTING BRIEFING AND HEARING SCHEDULE; AND CONTINUING CASE MANAGEMENT CONFERENCE MAXINE M. CHESNEY , District Judge . STIPULATION AND [PROPOSED] ORDER In support of this Stipulation, the Parties stipulate and agree as follows: WHEREAS, on April 24, 2017, Plaintiffs filed the Complaint against Defendants; WHEREAS, on September 29, 2017, the Court held a hearing on Defendants' motion to dismis
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STIPULATION AND [PROPOSED] ORDER CONTINUING PLAINTIFFS' DEADLINE TO FILE FIRST AMENDED COMPLAINT; SETTING BRIEFING AND HEARING SCHEDULE; AND CONTINUING CASE MANAGEMENT CONFERENCE

STIPULATION AND [PROPOSED] ORDER

In support of this Stipulation, the Parties stipulate and agree as follows:

WHEREAS, on April 24, 2017, Plaintiffs filed the Complaint against Defendants;

WHEREAS, on September 29, 2017, the Court held a hearing on Defendants' motion to dismiss the Complaint, and granted the motion with leave to amend the Complaint (See Dkt. #27);

WHEREAS, the Court ordered that Plaintiffs shall file a First Amended Complaint ("FAC") no later than October 27, 2017, and scheduled the Initial Case Management Conference for January 19, 2018 (Dkt. #25, 27);

WHEREAS, the Parties anticipate that Defendants will file a motion to dismiss the FAC;

WHEREAS, the Thanksgiving Day, Christmas Day, and New Year's Day Court holidays fall during the default briefing and hearing schedule for the anticipated motion;

WHEREAS, counsel for Defendants has a previously scheduled arbitration hearing from March 19, 2017 through March 23, 2017;

WHEREAS, the following time modifications have been made in the case, whether by stipulation or Court order:

• the initial Case Management Conference has been continued from July 28, 2017 three times, and is currently set for January 19, 2018 (Dkt. #15, 17, 25); • Defendants' deadline to respond to the Complaint was continued from May 18, 2017 to June 28, 2017 (Dkt. #17); • Plaintiffs' deadline to file an opposition to Defendants' motion to dismiss the Complaint was continued from July 12, 2017 to August 11, 2017 (Dkt. #17); • Defendants' deadline to file a reply in support of the motion to dismiss was continued from July 19, 2017 to August 25, 2017 (Dkt. #17); • the hearing on Defendants' motion to dismiss was continued from August 25, 2017 to September 29, 2017 (Dkt. #17);

WHEREAS, the Parties stipulate and respectfully request that the Court: continue Plaintiffs' deadline to file the FAC by two weeks, to November 10, 2017; set the below briefing schedule for Defendants' anticipated motion to dismiss the FAC; and continue the Initial Case Management Conference and corresponding deadlines, as set forth below;

WHEREAS, the Parties do not believe the requested continuance will have any effect on the overall schedule for this case;

NOW THEREFORE, in light of the intervening holidays and trial schedule for counsel, the Parties stipulate and respectfully request that the following schedule govern the case:

DATE EVENT November 10, 2017 Plaintiffs' deadline to file First Amended Complaint December 8, 2017 Defendants' deadline to file Motion to Dismiss January 12, 2018 Plaintiffs' deadline to file response to Motion to Dismiss January 26, 2018 Defendants' deadline to file reply to Plaintiffs' response February 9, 2018 Hearing on Motion to Dismiss at 9:00 a.m. March 9, 2018 Last day to meet and confer regarding Rule 26 initial disclosures, early settlement, ADR process selection, and discovery plan; File ADR Certification; File either Stipulation to ADR Process or Notice of Need for ADR Phone Conference March 23, 2018 Last day to file Rule 26(f) report, complete initial disclosures or state objection in Rule 26(f) report and file Case Management Statement March 30, 2018 Initial Case Management Conference at 10:30 a.m.

DECLARATION

Pursuant to Local Rule 6-2, I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

ATTESTATION PURSUANT TO CIVIL L.R. 5-1(i)(3)

I, Harmeet K. Dhillon, am the ECF User whose ID and password are being used to file this document. I hereby attest that concurrence in the filing of this document has been obtained from the signatories.

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Source:  Leagle

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