UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
December 3, 2012
LEON KHASIN, AN INDIVIDUAL, ON HIS OWN BEHALF AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
THE HERSHEY COMPANY, DEFENDANT.
The opinion of the court was delivered by: Edward J. Davila United States District Judge
EXTENDING TIME TO FILE UPDATED STIPULATION AND [PROPOSED] ORDER 16 JOINT CASE MANAGEMENT 17 STATEMENT AND ANSWER
Plaintiff Leon Khasin ("Plaintiff") and Defendant The Hershey Company ("Hershey"), through their undersigned counsel, hereby stipulate as follows:
WHEREAS, the Court entered an Order on November 21, 2012, directing the 25 parties to file an updated Joint Case Management Statement on or before December 7, 2012; 26 WHEREAS, the Court entered an Order on November 19, 2012, directing that 27 Hershey file an Answer to the Amended Complaint on or before December 21, 2012;
WHEREAS, Hershey recently decided to replace its existing counsel, Morrison & Foerster LLP, with the New York City firm of Patterson Belknap Webb & Tyler LLP, along with local counsel yet to be retained (together "Replacement Counsel");
WHEREAS, Hershey intends to file a Motion for Substitution of Counsel as soon as it has retained local counsel;
WHEREAS, Hershey has requested a brief adjournment of the above deadlines in order to allow Replacement Counsel an opportunity to familiarize itself with the background of this Action, and to effectuate the transfer of responsibility from Morrison & Foerster LLP to Replacement Counsel; and WHEREAS, Khasin does not oppose, and joins in, this request;
THE PARTIES HEREBY STIPULATE, subject to the approval of the Court, that: 1. The parties shall have an additional fourteen (14) days to file an updated Joint Case Management Statement, up to and including December 21, 2012; and 14 2. Hershey shall have an additional twenty-one (21) days to file an Answer to the 15 Amended Complaint, up to and including January 11, 2013.
Dated: December 4, 2012 William L. Stern (CA SBN 96105) MORRISON & FOERSTER LLP 19 By: /s/ William L. Stern_________________ 20 William L. Stern 21 Attorneys for Defendant THE HERSHEY COMPANY 22 23 Dated: December 4, 2012 Ben F. Pierce Gore (SBN 128515) 24 PRATT & ASSOCIATES 25 By: /s/ Ben F. Pierce Gore_________________ Ben F. Pierce Gore 26 27 Attorneys for Plaintiff
MANAGEMENT STATEMENT AND ANSWER [PROPOSED] ORDER PURSUANT TO STIPULATION OF THE PARTIES, IT IS SO ORDERED.
I, William L. Stern, am the ECF User whose ID and password are being used to file the 3 following: STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE 4 UPDATED JOINT CASE MANAGEMENT STATEMENT AND ANSWER. In compliance 5 with General Order 45, X.B., I hereby attest that Ben F. Pierce Gore has concurred in this filing.
WILLIAM L. STERN Dated: December 4, 2012 8 WILLIAM F. TARANTINO CLAUDIA M. VETESI MORRISON & FOERSTER LLP By: /s/ William L. Stern 11 WILLIAM L. STERN
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