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The Federal Defendants are specially appearing for the purposes of filing this

stipulation.

STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

CV-09-2890 TEH

JOSEPH P. RUSSONIELLO (CABN 44332)

United States Attorney

JOANN M. SWANSON (CSBN 88143)

Chief, Civil Division

MELISSA K. BROWN (CSBN 203307)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-6962

FAX: (415) 436-6748

melissa.k.brown@usdoj.gov

Attorneys for Defendants

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

LUDWIK CHROBOK,

Plaintiff,

v.

UNITED STATES OF AMERICA,

VETERANS ADMINISTRATION

Defendant. 

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No. CV-09-2890 TEH

E-FILED

STIPULATION AND [PROPOSED]

ORDER TO CONTINUE INITIAL CASE

MANAGEMENT CONFERENCE AND

TIME FOR FEDERAL DEFENDANT TO

FILE A RESPONSIVE PLEADING

The plaintiff Ludwik Chrobok, (“Plaintiff”) and the federal defendants United States of

America and Veterans Administration (“Federal Defendants”)1

 by and through their counsel

stipulate to the following:

WHEREAS Plaintiff filed his complaint in the above-captioned action on June 26, 2009

and served the United States Attorneys Office for the Northern District of California, San

Francisco on or about November 9, 2009;

WHEREAS, pursuant to Rule l2(a)(3)(A) and (B) of the Federal Rules of Civil

Procedure, the United States or its officers or agencies have sixty (60) days after service upon

Case 3:09-cv-02890-TEH Document 12 Filed 01/08/10 Page 1 of 3
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

CV-09-2890 TEH

the U.S. Attorney to file an answer or other response to a complaint and currently a responsive

pleading is due on January 8, 2010;

WHEREAS, the Initial Case Management Conference in the above-captioned action is

currently scheduled for January 11, 2010 at 1:30 p.m.;

WHEREAS, the Plaintiff and Federal Defendants (collectively “the parties”) participated

in mediation proceedings on December 17, 2009 and are continuing discussions at least through

January 15, 2010;

ACCORDINGLY, the parties agree and stipulate as follows:

The parties respectfully request that the Initial Case Management Conference currently

scheduled in this case for January 11, 2010 at 1:30 p.m. be continued to February 15, 2010 at

1:30 p.m. The parties further agree that the Federal Defendant shall have until February 8, 2010

to file a responsive pleading in this action.

So Stipulated.

DATED: January 7, 2010 Respectfully submitted,

JOSEPH P. RUSSONIELLO

United States Attorney

/s/ Melissa Brown ________________________________

MELISSA K. BROWN

Assistant United States Attorney

DATED: January 7, 2010

MARK J. ALEXANDER

Law Offices of Mark J. Alexander

/s/ Mark J. Alexander

________________________________

MARK J. ALEXANDER

Attorney for the Plaintiff

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

CV-09-2890 TEH

[PROPOSED ] ORDER

Pursuant to the stipulation of the parties, the Initial Case Management Conference

currently scheduled in this case for January 11, 2010 at 1:30 p.m. is continued to March 1,

2010 at 1:30 p.m. Further, the Federal Defendant shall have until February 8, 2010 to file and

serve a responsive pleading.

IT IS SO ORDERED

Dated: _______________ ____________________________

HON. THELTON E. HENDERSON

United States District Court Judge

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

Judge Thelton E. Henderson

01/07/10

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