SECOND STIPULATED REQUEST FORORDERCHANGINGTIME Civ. L.R. 6-1(b), 6-2(a), 7-12
Pursuant to Civil Local Rules 6-1(b), 6-2(a) and 7-12, Plaintiffs Kinfong Sit and Mee Wai Chiu ("Plaintiffs") and Defendant Genentech, Inc. Tax Reduction Investment Plan (the "Plan"), 26 by their respective counsel, stipulate and agree as follows: 27
1. On October 4, 2012, Plaintiffs filed a motion to remand this case back to state 28 court, Dkt. No. 18, a motion for a preliminary injunction, Dkt. No. 19, and a motion for sanctions
2. The Plan's responses to these motions originally were due to be filed on or before October 18, 2012. 4
3. On October 4 and 16, 2012, counsel for Plaintiffs and the Plan conferred by 5 telephone with respect to Plaintiffs' motions and the related briefing schedules. 6
4. Plaintiffs agreed to extend the deadline for the Plan to respond to the motions by
7 two weeks, to November 1, 2012, in order to permit Plaintiffs and the Plan additional time to 8 confer in an effort to reach an amicable resolution of the issues raised in the motions. 9
5. On October 16, 2012, the parties filed a stipulation to that effect. See Dkt. No. 29.
6. On October 23, 2012, the Court entered an order resetting the response deadlines
11 for all three motions to November 1, 2012. See Dkt. No. 35. 12
7. Since that time, including on October 23, 2012 and October 29, 2012, counsel for
Plaintiffs and the Plan have further conferred to try to resolve Plaintiffs' motions. The parties 14 also have discussed a potential stipulation regarding case management matters, a part of which 15 will involve Plaintiffs' withdrawal of the pending motions. The parties' negotiations in that 16 regard are ongoing. 17
8. Accordingly, the parties respectfully request that the Court again continue the
18 response deadlines for the three pending motions so that they may conclude efforts to resolve the 19 pending motions without need for the Court's involvement. Should those efforts not result in the 20 withdrawal of the motions, the ...