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REED SMITH LLP 

A limited liability partnership formed in the State of Delaware

Belynda S. Reck (SBN 163561)

Email: breck@reedsmith.com

Anthony S. Newman (SBN 235514)

Email: anewman@reedsmith.com

Jonathan D. Gershon (SBN 306979)

Email: jgershon@reedsmith.com

REED SMITH LLP

355 South Grand Avenue, Suite 2900

Los Angeles, CA 90071-1514

Telephone: +1 213 457 8000

Facsimile: +1 213 457 8080

Attorneys for Specially Appearing Defendant and 

Cross-Defendant Hanson Building Materials Limited

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA

THE SUCCESSOR AGENCY TO THE 

FORMER EMERYVILLE REDEVELOPMENT 

AGENCY AND THE CITY OF 

EMERYVILLE,

Plaintiffs,

vs.

SWAGELOK COMPANY, an Ohio corporation; 

WHITNEY RESEARCH TOOL CO., a 

dissolved California corporation; HANSON, a 

British Corporation; CATHERINE LENNON 

LOZICK, an individual residing in Ohio,

Defendants.

Case No. 17-cv-00308-WHO

STIPULATION AND ORDER BY THE 

SUCCESSOR AGENCY TO THE 

FORMER EMERYVILLE 

REDEVELOPMENT AGENCY AND 

THE CITY OF EMERYVILLE, 

SWAGELOK COMPANY, 

CATHERINE LENNON LOZICK, 

WHITNEY RESEARCH TOOL CO., 

AND SPECIALLY APPEARING 

PARTY HANSON BUILDING 

MATERIALS LIMITED REGARDING 

EXTENSION OF TIME FOR 

BRIEFING SCHEDULE FOR 

HANSON’S MOTION TO DISMISS

Judge: Hon. William H. Orrick 

Action Filed: January 20, 2017

AND RELATED COUNTERCLAIMS AND 

CROSS CLAIMS

Plaintiffs The Successor Agency to the former Emeryville Redevelopment Agency and the 

City of Emeryville (collectively, “Plaintiffs”), Defendants Swagelok Company (“Swagelok”), 

Catherine Lennon Lozick (“Lozick”), Whitney Research Tool Co. (“Whitney”), and specially 
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REED SMITH LLP 

A limited liability partnership formed in the State of Delaware

appearing party Hanson Building Materials Limited (“HBML”) (collectively, the “Parties”), by and 

through their respective counsel of record, hereby stipulate and agree as follows:

WHEREAS, on September 24, 2018, pursuant to stipulation of the Parties, the Court entered 

an Order extending the briefing schedule and hearing date on HBML’s motion to dismiss Plaintiffs’ 

Second Amended Complaint and related crossclaims under Federal Rule of Civil Procedure 12(b)(2) 

for lack of personal jurisdiction as follows (Dkt. No. 110):

1. Any reply(ies) by HBML in support of its Rule 12 motion shall be filed on or before 

October 23, 2018;

3. The Court’s hearing on this matter shall be November 7, 2018, at 2 p.m. in 

Courtroom 2. (Dkt No. 104)

WHEREAS, HBML is located in England, in a different time zone to its counsel (the 

difference is 8 hours), and believes that coordinating multiple Replies on separate issues will 

increase the existing time-related and communication challenges; 

WHEREAS, HBML has never independently sought an extension of time; 

WHEREAS, HBML now seeks a two-week extension to file Replies to the three Oppositions 

filed by Swagelok, Lozick and the Plaintiffs, and will file such Replies in accordance with the 

Federal Rules of Civil Procedure and the Local Rules of the Northern District of California (and 

relevant case law interpreting such rules); 

WHEREAS, the Parties have met and conferred regarding a mutually agreeable hearing date;

WHEREAS, the Parties agree that this will be the final change to the briefing and hearing 

schedule sought by any party and; 

WHEREAS, HBML continues to reserve all defenses under Rule 12, including without 

limitation lack of personal jurisdiction, and by the filing of this stipulation, HBML does not concede, 

and Plaintiffs will not argue, that this Court has personal jurisdiction over HBML because of the 

submission of this Stipulation.

IT IS HEREBY STIPULATED AND AGREED by and between and among Plaintiffs, 

Swagelok, Lozick, Whitney, and HBML that:
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- 3 -

REED SMITH LLP 

A limited liability partnership formed in the State of Delaware

1. Any reply(ies) by HBML in support of its Rule 12 motion shall be filed on or before 

November 6, 2018; and

2. The Court’s hearing on this matter shall be held on December 12, 2018, at 2 p.m. in 

Courtroom 2.

Pursuant to Local Rule 5-1(i)(3), the filer, Belynda Reck, attests that all other signatories 

listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized 

the filing.
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REED SMITH LLP 

A limited liability partnership formed in the State of Delaware

Dated: October 9, 2018 WENDEL ROSEN BLACK & DEAN LLP

By: /s/ Christine K. Noma

Christine K. Noma

Attorneys for Defendant 

CATHERINE LENNON LOZICK

Dated: October 9, 2018 COX, CASTLE & NICHOLSON LLP

By: /s/ Robert P. Doty

Robert P. Doty 

Attorneys for Plaintiffs

THE SUCCESSOR AGENCY TO THE FORMER 

EMERYVILLE REDEVELOPMENT AGENCY 

AND THE CITY OF EMERYVILLE

Dated: October 9, 2018 BAKER & HOSTETLER LLP

By: /s/ Joelle A. Berle

Joelle A. Berle

Attorneys for Defendants 

SWAGELOK COMPANY and WHITNEY 

RESEARCH TOOL CO.

Dated: October 9, 2018 MANSOUR GAVIN

By: /s/ Jeffrey M. Embleton

Jeffrey M. Embleton

Attorneys for Defendant 

CATHERINE LENNON LOZICK

Dated: October 9, 2018 REED SMITH LLP

By: /s/ Belynda S. Reck

Belynda S. Reck

Attorneys for Specially Appearing Party

HANSON BUILDING MATERIALS LIMITED
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REED SMITH LLP 

A limited liability partnership formed in the State of Delaware

ORDER

GOOD CAUSE APPEARING, the Court hereby adopts the above-referenced schedule as the 

Order of the Court.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED: October 10, 2018

Honorable William H. Orrick 

United States District Court