STIPULATION AND [PROPOSED] ORDER ENLARGING TIME TO FILE BRIEFS [CIVIL LOCAL RULES 6-1, 6-2, AND 7-12]
WHEREAS, defendant Safeway Inc. ("Safeway") removed this case from the Superior Court of the State of California for the County of Alameda to this Court on March 14, 2011;
WHEREAS, pursuant to Local Rule 6-1(a), the parties to this proceeding have previously stipulated to enlarge the time for Safeway to answer or otherwise respond to plaintiffs' complaint to April 4, 2011; and
WHEREAS, plaintiffs have requested an extension of the briefing schedule if a motion challenging the complaint is filed by Safeway and Safeway so consents;
WHEREAS, pursuant to Civil Local Rule 6-2(a), counsel for Safeway is concurrently filing a declaration in support of this Stipulation and [Proposed] Order;
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the undersigned counsel for the parties as follows:
1. Plaintiffs will file any opposition to a motion challenging the complaint on May 9,2011;
2. Safeway will file any reply to plaintiffs' opposition brief on May 23, 2011; and
3. Safeway will notice any motion challenging the complaint for a hearing during the week of June 6, 2011, or the Court's next available date for law and motion.
IT IS SO STIPULATED AND AGREED.
Authority for and concurrence in the filing of this stipulation has been obtained from each of the signatories, pursuant to General Order 45 X.B.
Dated: March 21, 2011 Respectfully submitted, LATHAM & WATKINS LLP Stephen Stublarec Belinda S Lee Betsy A. Williams By Belinda S Lee Attorneys for Defendant Dated: March 21, 2011 Respectfully submitted, CONSUMER LAW PRACTICE OF DANIEL T. LEBEL By Daniel T. LeBel Attorney for Plaintiffs
PURSUANT TO STIPULATION, IT IS ...