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Hamidi v. Service Employees International Union

United States District Court, E.D. California

February 25, 2014

KOUROSH KENNETH HAMIDI, et al.,
v.
SERVICE EMPLOYEES INTERNATIONAL UNION, LOCAL 1000, et al.; Defendants. AND THE CLASS THEY SEEK TO REPRESENT Plaintiffs,

JEFFREY B. DEMAIN, Altshuler Berzon LLP, San Francisco, California.

J. FELIX DE LA TORRE, ANNE M. GIESE, Sacramento, California, Attorneys for Defendant. Service Employees International Union, Local 1000.

Kim L. Nguyen, Deputy Attorney General Government Law Section Department of Justice, Office of the Attorney General, Los Angeles, California.

Mark Beckington, Supervising Deputy Attorney General California Department of Justice, Los Angeles, California. Attorneys for Defendant John Chiang, Controller of the State of California.

W. JAMES YOUNG, Esq., c/o National Right to Work Legal Defense Foundation, Inc., Springfield, Virginia.

STEVEN R. BURLINGHAM, Esq., Gary, Till & Burlingham, Sacramento, California. Attorneys for Plaintiffs and the Class They Seek to Represent.

STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT; [PROPOSED] ORDER THEREON

GARLAND E. BURRELL, Jr., Senior District Judge.

STIPULATED REQUEST FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

The parties to the above-captioned case, by and through their undersigned counsel of record, hereby respectfully request that defendants be granted until and including April 25, 2014, to respond to plaintiffs' Complaint. In support of that request, the parties state as follows:

1. The responsive pleading on behalf of defendant John Chiang, Controller of the State of California, is currently due on February 24, 2014. The requested extension until and including April 25, 2014 will afford Secretary Chiang a sixty-day extension of time to respond to the Complaint.

2. The responsive pleading on behalf of the other defendant in this case, Service Employees International Union Local 1000, is currently due on March 4, 2014. The requested extension until and including April 25, 2014 will afford Local 1000 a fifty-two-day extension of time to respond to the Complaint.

3. No previous extensions of time to respond to the Complaint have been requested or granted in this case.

4. The requested extension of time is necessary because defendants have only recently secured counsel to represent them in this case, plaintiffs' Complaint contains numerous factual allegations that counsel must investigate in order to prepare responsive pleadings, and defendants' counsel have numerous litigation commitments that will require their attention in the next sixty days.

5. The requested extension of time will not require the Court to reschedule any pretrial dates previously scheduled in this case.

The foregoing is hereby stipulated among the parties in this action, who respectfully request the Court to grant the extension of time.

[PROPOSED] ORDER

IT IS SO ORDERED.


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