Filed: Jul. 18, 2019
Latest Update: Jul. 18, 2019
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO ENLARGE DEADLINES AND TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT JAMES DONATO , District Judge . Plaintiff Kevin Pegram ("Plaintiff") and Defendant Megan J. Brennan ("Defendant"), by and through their undersigned counsel, hereby jointly stipulate as follows: WHEREAS, on May 10, 2019 Plaintiff filed a complaint in the above-entitled action; and WHEREAS, on June 25, 2019 Plaintiff served the Complaint and Summons on the Office
Summary: JOINT STIPULATION AND [PROPOSED] ORDER TO ENLARGE DEADLINES AND TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT JAMES DONATO , District Judge . Plaintiff Kevin Pegram ("Plaintiff") and Defendant Megan J. Brennan ("Defendant"), by and through their undersigned counsel, hereby jointly stipulate as follows: WHEREAS, on May 10, 2019 Plaintiff filed a complaint in the above-entitled action; and WHEREAS, on June 25, 2019 Plaintiff served the Complaint and Summons on the Office o..
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JOINT STIPULATION AND [PROPOSED] ORDER TO ENLARGE DEADLINES AND TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
JAMES DONATO, District Judge.
Plaintiff Kevin Pegram ("Plaintiff") and Defendant Megan J. Brennan ("Defendant"), by and through their undersigned counsel, hereby jointly stipulate as follows:
WHEREAS, on May 10, 2019 Plaintiff filed a complaint in the above-entitled action; and
WHEREAS, on June 25, 2019 Plaintiff served the Complaint and Summons on the Office of the U.S. Attorney for the Northern District of California; and
WHEREAS, Defendant has requested additional time to respond to the Complaint; and
WHEREAS, the Parties have agreed that Defendant may have until September 23, 2019 to answer or otherwise respond to the Complaint in the form of a Rule 12 motion;
WHEREAS, the Parties have further agreed to alter the initial case management deadlines set forth in this Court's Case Management Order (Dkt. 4).
NOW THEREFORE, the parties hereby STIPULATE, pursuant to Local Rule 6-1(a), that the time within which Defendant shall answer or otherwise respond to the Complaint shall be extended to September 23, 2019. To the extent that Defendant files a motion pursuant to Rule 12, the time within which Defendant thereafter shall answer or otherwise respond shall be governed by Federal Rule of Civil Procedure 12(a)(4). The Parties further stipulate to enlarge the deadlines in the May 10, 2019 Order (Dkt. 4), such that they shall meet and confer regarding initial case management matters by October 18, 2019, and they will file a joint case management statement by October 24, 2019. If the Court's schedule permits, the Parties will hold an initial case management conference on October 31, 2019.
Dated: July 15, 2019 Respectfully submitted,
DAVID L. ANDERSON
United States Attorney
/s/ Kimberly A. Robinson
KIMBERLY A. ROBINSON
Assistant United States Attorney
Attorneys for Defendant
Dated: July 15, 2019 /s/ Dow W. Patten
DOW WAKEFIELD PATTEN
Attorney for Plaintiff
* In compliance with Civil Local Rule 5-1(i)(3), the filer of this document attests under penalty of perjury that counsel for Plaintiff has concurred in the filing of this document.
[PROPOSED] ORDER
IT IS HEREBY ORDERED that Defendant shall answer or otherwise respond to the Complaint by September 23, 2019. Further, the deadlines in the May 10, 2019, Order are enlarged as follows: The Parties shall meet and confer regarding initial case management matters by October 18, 2019. They shall file a joint case management statement by October 24, 2019. The Parties will hold an initial case management conference on October 31, 2019 at 10:00 a.m. in Courtroom 11, 19th Floor Phillip Burton Federal Building 450 Golden Gate Avenue San Francisco, CA 94102.
