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Chattler v. United States Dep't of State

December 5, 2007

JULIE CHATTLER, ON BEHALF OF HERSELF AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
THE UNITED STATES DEPARTMENT OF STATE, DEFENDANTS.



The opinion of the court was delivered by: The Honorable Susan Illston United States District Court Judge

STIPULATION AND [PROPOSED] ORDER REGARDING BRIEFING SCHEDULE AND HEARING DATE OF PLAINTIFF'S MOTION TO STAY THE UNITED STATES OF AMERICA and ) RULING ON MOTION TO DISMISS

ACTION FILED: August 7, 2007

Fair Dealing ("Complaint");

WHEREAS on August 7, 2007, Plaintiff Chattler filed her Class Action Complaint for Breach of Contract, Regulatory Violation, and Breach of the Implied Covenant of Good Faith and

WHEREAS on October 9, 2007, the United States of America and the United States Department of State (collectively "Defendants") filed a motion to dismiss the Complaint; dismiss, and concurrently therewith, filed Plaintiff's Motion to Stay Ruling on Motion to Dismiss

WHEREAS Plaintiff believes that the issues in Plaintiff's Motion to Stay Ruling largely overlap with those raised in Plaintiff's opposition to the motion to dismiss; to approval by the Court, to shorten the time for Plaintiff's Motion to Stay Ruling; stipulation and Court order, the re-scheduling of the Initial Case Management Conference from

WHEREAS this stipulation and order shortening time on the hearing for Plaintiff's Motion to Stay Ruling will have no further impact on the schedule for this case; undersigned counsel for Plaintiff and counsel for Defendants, subject to the approval of the Court, that: 2007; , 2007; and

WHEREAS on November 30, 2007, Plaintiff filed an opposition to Defendants' motion to ("Motion to Stay Ruling");

WHEREAS for the sake of efficiency and to reduce costs, the parties have agreed, subject

WHEREAS the only previous time modification to the schedule in this case has been, by December 7, 2007 to January 18, 2008 at 2:00 p.m.; and

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the

1. Defendants shall file their opposition to the Motion to Stay Ruling on December 14,

2. Plaintiff shall file her reply in support of the Motion to Stay Ruling on December

3. The hearing on the Motion to Stay Ruling shall be on December 21, 2007 at 9:00 2 a.m., at the same date and time as the ...


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