1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Robert B. Jobe (Cal. State Bar #133089)

LAW OFFICE OF ROBERT B. JOBE

550 Kearny St., Ste. 200

San Francisco, CA 94108

Tel: (415) 956-5513

Fax: (415) 840-0308

Email: bob@jobelaw.com

Attorney for Plaintiffs.

UNITED STATES DISTRICT COURT FOR THE 

NORTHERN DISTRICT OF CALIFORNIA

TANIA GARCIA-LOPEZ ET AL., ) No. 3:09-cv-2592 RS

)

Plaintiff, )

 )

v. ) STIPULATION TO EXTEND THE 

) DEADLINE FOR PLAINTIFFS’ REPLY

MICHAEL AYTES, ET AL., ) TO THE DEFENDANTS’ OPPOSITION 

) TO THE CROSS MOTION FOR

Defendants. ) SUMMARY JUDGMENT; 

) [PROPOSED] ORDER

)

) Date: June 10, 2010

) Time: 1:30 p.m.

____________________________________) Honorable Richard Seeborg

Plaintiffs, by and through their attorney of record, and Defendants, by and through their

attorneys of record, hereby stipulate, subject to the approval of the Court, to extend the deadline

for Plaintiffs’ reply to the Defendants’ Opposition to Plaintiffs’ Cross Motion for Summary

Judgment, currently set for April 16, 2010, on the following grounds:

1. Defendants filed an Opposition to Plaintiffs’ Cross Motion for Summary

Judgment on April 2, 2010. Plaintiffs’ reply to that motion is currently due on April 16, 2010,

and the hearing on both motions is set for June 10, 2010 at 1:30 p.m. 

2. Because the hearing on these motions is not until June, and because Plaintiffs’

counsel is experiencing a heavy caseload, Plaintiffs’ counsel respectfully requests that due date

for the reply be extended to May 14, 2010.

3. Defendants’ counsel has indicated that he has no opposition to resetting the

Stipulation to Extend Deadline; [Proposed] Order

No. 3:09-cv-2592 RS

DENYING STIPULATION AS 

UNNECESSARY

*E-Filed 4/7/10*

Case 3:09-cv-02592-RS Document 26 Filed 04/07/10 Page 1 of 2
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

briefing schedule as set forth below.

4. Accordingly, the parties respectfully request that, pursuant to their stipulation, the 

Court reset the deadline for Plaintiffs’ Reply to Defendants’ Opposition to Plaintiffs’ CrossMotion for Summary Judgment as follows:

Plaintiffs’ Reply to Opposition to Cross-Motion for Summary Judgment: 5/14/2010

Dated: April 7, 2010 Respectfully submitted,

/s/ Robert B. Jobe

 

ROBERT B. JOBE

Attorney for Plaintiffs

Dated: April 7, 2010 JOSEPH P. RUSSONIELLO

United States Attorney

TONY WEST

United States Attorney Assistant Attorney General

JOSHUA E. BRAUNSTEIN

Assistant Director

/s/ Jonathan D. Wasden

_________________________________________

JONATHAN D. WASDEN

Trial Attorney

United States Department of Justice Civil Division

Attorneys for Defendants

[PROPOSED] ORDER

Pursuant to stipulation, IT IS HEREBY ORDERED that the deadline for Plaintiffs’ Reply

to Defendants’ Opposition to Cross-Motion for Summary Judgment be reset as follows:

Plaintiffs’ Reply to Opposition to Cross-Motion for Summary Judgment: 5/14/2010

 IT IS SO ORDERED.

Dated: _______________________________

RICHARD SEEBORG

UNITED STATES DISTRICT JUDGE

Stipulation to Extend Deadline; [Proposed] Order

No. 3:09-cv-2592 RS

The Parties' stipulation is DENIED as unnecessary. The briefing schedule is to be calculated from the continued hearing date. See 

Civil Local Rule 7-7(d).

April 7, 2010

Case 3:09-cv-02592-RS Document 26 Filed 04/07/10 Page 2 of 2