UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
August 14, 2008
MARK MURRAY, PLAINTIFF,
THE ABBOTT SEVERANCE PAY PLAN FOR FORMER U.S. GUIDANT EMPLOYEES, 2006 EDITION, DEFENDANT.
The opinion of the court was delivered by: Hon. James Ware United States District Court Judge
STIPULATION REGARDING EXTENSION OF TIME FOR FILING JOINT BACKGROUND AND UNDISPUTED STATEMENT OF FACTS AND CROSS-MOTIONS FOR SUMMARY JUDGMENT AND PROPOSED ORDER
This stipulation is entered into by and among Plaintiff Mark Murray ("Mr. Murray") and Defendant The Abbott Severance Pay Plan for Former U.S. Guidant Employees, 2006 Edition (the "Plan") (collectively the "Parties"), through their respective attorneys of record.
WHEREAS Local Civil Rule 6-2 allows the parties to file a stipulation requesting an order to extend the deadlines in a case. Pursuant to Local Rule 6-2, the Parties submit the following stipulation:
1. On May 29, 2005, this Court entered a Scheduling Order in the above-referenced matter setting the following dates:
* August 15, 2008-filing of a Joint Background and Undisputed Statement of Facts as well as cross-motions for summary judgment
* August 29, 2008-oppositions, if any
* September 5, 2008-replies, if any
2. The Parties stipulate to, and ask the Court to enter, an Order extending these dates by seven (7) additional days in order to fully collaborate on the Joint Background and Undisputed Statement of Facts.
3. The Parties previously twice stipulated to an extension of time to file a response to Plaintiff's Complaint on March 4, 2008 and on March 25, 2008.
4. The requested time modification will push back all deadlines by (7) seven days, but should not effect the October 6, 2008 hearing date. All briefing will end on September 12, 2008, over three weeks prior to the scheduled hearing date.
The PARTIES HEREBY STIPULATE and request the Court amend the Scheduling
Order with the following dates:
* August 22, 2008-filing of a Joint Background and Undisputed Statement of Facts as well as cross-motions for summary judgment
* September 5, 2008-oppositions, if any
* September 12, 2008-replies, if any
WINSTON & STRAWN LLP 22 Joseph J. Torres Attorney for Defendant THE ABBOTT SEVERANCE PAY PLAN FOR FORMER U.S. GUIDANT EMPLOYEES, 2006 EDITION
Dated: August 13, 2008
DELFINO GREEN & GREEN William Green, Esq. Attorney for Plaintiff MARK MURRAY
PURSUANT TO STIPULATION, IT IS SO ORDERED.
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