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STIPULATION AND [PROPOSED] ORDER RE. 

EXTENDING OPPOSITION AND REPLY DEADLINES

CASE NO. 17-CV-00308-WHO

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LAW OFFICES OF

COX, CASTLE & 

NICHOLSON LLP

SAN FRANCISCO, CA

Robert P. Doty (SBN 148069)

rdoty@coxcastle.com

Ali P. Hamidi (SBN 191198)

ahamidi@coxcastle.com

Trevor B. Potter (SBN 265287)

tpotter@coxcastle.com

COX, CASTLE & NICHOLSON LLP

50 California Street, Suite 3200

San Francisco, CA 94111

Telephone: (415) 262-5100

Facsimile: (415) 262-5199

Attorneys for Plaintiffs

The Successor Agency to the former Emeryville 

Redevelopment Agency and The City of Emeryville

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 BUILDING MATERIALS 

LIMITED, a British Corporation; and 

CATHERINE LENNON LOZICK, an 

individual residing in Ohio,

Defendants.

Case No. 17-cv-00308-WHO

STIPULATION AND [PROPOSED] 

ORDER BY PLAINTIFFS AND 

SPECIALLY APPEARING PARTY 

HANSON BUILDING MATERIALS 

LIMITED REGARDING EXTENDING 

OPPOSITION AND REPLY 

DEADLINES TO HANSON BUILDING 

MATERIALS LIMITED’S MOTION 

FOR SUMMARY JUDGMENT

Judge: Hon. William H. Orrick

Complaint Filed: January 20, 2017

AND RELATED COUNTERCLAIMS AND 

CROSSCLAIMS

Case 3:17-cv-00308-WHO Document 236 Filed 01/25/23 Page 1 of 4
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STIPULATION AND [PROPOSED] ORDER RE. 

EXTENDING OPPOSITION AND REPLY DEADLINES

CASE NO. 17-CV-00308-WHO

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LAW OFFICES OF

COX, CASTLE & 

NICHOLSON LLP

SAN FRANCISCO, CA

Pursuant to Civil Local Rule 6-2, Plaintiffs The Successor Agency to the former 

Emeryville Redevelopment Agency and the City of Emeryville (collectively, “Plaintiffs”), and 

specially 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, in accordance with the Court’s Scheduling Order (DKT No. 211), on January 

20, 2023, HBML filed its Motion for Summary Judgment Or, in the Alternative, Summary 

Adjudication (“Dispositive Motion”) (DKT No. 234), currently scheduled to be heard on 

March 8, at 2 pm;

WHEREAS, pursuant to the Court’s Scheduling Order (DKT No. 211), Plaintiff’s 

Opposition to the Dispositive Motion (“Opposition”) is due on February 3, 2023;

WHEREAS, HBML’s Reply to the Opposition is due on February 10, 2023; 

WHEREAS, Plaintiffs have requested, and HBML does not oppose, additional time to 

complete the briefing on HBML’s motion;

WHEREAS, a short extension in the deadlines for the Opposition and Reply papers will 

not necessitate the continuance of the scheduled March 8, 2023 hearing, or any other subsequent 

deadline set either by Court order or the local rules;

SUBJECT TO THE COURT’S APPROVAL, IT IS HEREBY STIPULATED AND 

AGREED by and between and among Plaintiffs HBML that:

1. The Court’s existing scheduling order, be modified only as follows:

Event Current Deadline New Proposed Deadline

Plaintiff’s Brief in Opposition to 

HBML’s Dispositive Motion

February 3, 2022 February 10, 2023

HBML’s Reply to Opposition to 

HBML’s Dispositive Motion

February 10, 2022 February 22, 2023

///

///

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STIPULATION AND [PROPOSED] ORDER RE. 

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LAW OFFICES OF

COX, CASTLE &

NICHOLSON LLP

SAN FRANCISCO, CA

Respectfully submitted,

Dated: January 24, 2023 COX, CASTLE & NICHOLSON LLP

By: /s/ Ali P. Hamidi

Ali P. Hamidi1

Attorneys for Plaintiffs 

THE SUCCESSOR AGENCY TO THE FORMER 

EMERYVILLE REDEVELOPMENT AGENCY 

AND THE CITY OF EMERYVILLE

Dated: January 24, 2023 K&L GATES LLP

By: /s/ Jason Haycock

Jason Haycock

Attorneys for Defendant

HANSON BUILDING MATERIALS LIMITED

1 Pursuant to Civil Local Rule 5-1(h)(4), concurrence in the filing of this document has been 

obtained from HBML’s counsel. 

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STIPULATION AND [PROPOSED] ORDER RE. 

EXTENDING OPPOSITION AND REPLY DEADLINES

CASE NO. 17-CV-00308-WHO

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LAW OFFICES OF

COX, CASTLE &

NICHOLSON LLP

SAN FRANCISCO, CA

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS SO ORDERED:

1. The deadline for Plaintiffs to file their opposition to HBML’s dispositive motion is 

extended from February 3, 2023, to February 10, 2023. 

2. The deadline for HBML to file its reply to Plaintiffs’ opposition to HBML’s 

dispositive motion is extended from February 10, 2023, to February 22, 2023.

3. The hearing on HBML’s dispositive motion shall remain on March 8, 2023. 

IT IS SO ORDERED. 

DATED: January 25, 2023

Honorable William H. Orrick

United States District Court

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