COOPER, WHITE & COOPER LLP, CHRISTOPHER J. MEAD, (SBN 115091) SCOTT M. McLEOD, (SBN 242035) San Francisco, California, Attorneys for Defendant Ballet San Jose Silicon Valley, Inc. (erroneously sued as Ballet San Jose, Inc.)
KERR & WAGSTAFFE LLP, James M. Wagstaffe, Attorneys for Plaintiff Dennis Nahat.
STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION TO REMAND STATE LAW CLAIMS
SAUNDRA B. ARMSTRONG, District Judge.
The parties, by and through counsel, stipulate as follows:
1. On September 11, 2013 Plaintiff Dennis Nahat filed a Motion to Remand State Law Claims For Lack of Jurisdiction and, in the Alternative, Be Remanded in the Court's Statutory Discretion ("Motion to Remand"), set to be heard November 12, 2013 at 1:00 p.m. in Courtroom 1 before the Hon. Saundra B. Armstrong.
2. Defendant Ballet San Jose Silicon Valley, Inc. ("BSJ") was served on September 11, 2013, and its response is currently due on September 25, 2013, and Plaintiff's reply is due October 2.
3. BSJ seeks an extension of the time to respond because lead counsel for BSJ is out 729176.1 C 13-02896 SBA of the country from September 8 through September 22.
4. There have been no prior extensions of time regarding this motion. Plaintiff requested an extension of time to respond to Defendant's Motion to Dismiss. The parties stipulated to that extension, which the Court ordered on July 19, 2013. (Docket #15.)
5. The requested time modification will not have an effect on the schedule of the case as the Motion to Remand is set for hearing on November 12, 2013.
6. Pursuant to Civil Local Rule 6-2, the parties hereby stipulate that BSJ's response shall be due October 4, 2013 and any reply shall be due October 11, 2013.
Having reviewed the above stipulation submitted by the parties, and good cause appearing, the Court hereby orders the following:
1. The deadline for BSJ to respond to the Motion to Remand ...