Free Stipulation - District Court of California - California

Case 3:08-cv-04016-TEH

Document 8

Filed 08/29/2008

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DLA P IPER US LLP
E A S T P ALO A L T O

HOPE ANNE CASE (Bar No. 157089) ([email protected]) NORA CULVER (Bar No. 240098) ([email protected]) DLA PIPER US LLP 2000 University Avenue East Palo Alto, CA 94303-2215 Tel: 650.833.2000 Fax: 650.833.2001 Attorneys for Defendant UNITED AIR LINES, INC. UNITED STATES DISTRICT COURT, FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION LARRY OILUND Plaintiff, v. UNITED AIRLINES/WORLD HEADQUARTERS; GLEN F. TILTON; BARBARA LIATAUD; RON RICH; JIM BOLAND; VINNIE AGVATEESIRI; ANDRE ST. LOUIS DOES 1-20, INCLUSIVE, Defendants. CASE NO. C 08-04016 TEH STIPULATION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND FOR DISMISSAL WITHOUT PREJUDICE OF DEFENDANTS GLEN F. TILTON; BARBARA LIATAUD; RON RICH; JIM BOLAND; VINNIE AGVATEESIRI AND ANDRE ST. LOUIS

Pursuant to Local Rule 6-1 of the Northern District of California and Rule 41(a) of the Federal Rules of Civil Procedure, it is hereby stipulated and agreed by Plaintiff and Defendant UNITED AIR LINES, INC. ("Defendant"), by and through their attorneys, as follows: WHEREAS Defendant removed this case from the Superior Court for the County of San Mateo on August 22, 2008; WHEREAS the last day for Defendant to respond to Plaintiff's Complaint is August 27, 2008; WHEREAS Defendant desires a short extension of time to evaluate Plaintiff's allegations and to make an appropriate response;
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STIPULATION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND TO DISMISS INDIVIDUAL DEFENDANTS / CASE NO. C-08-04016 TEH

Case 3:08-cv-04016-TEH

Document 8

Filed 08/29/2008

Page 2 of 2

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DLA P IPER US LLP
E A S T P ALO A L T O

WHEREAS Plaintiff has agreed to dismiss its claims against Defendants Glen F. Tilton, Barbara Liataud, Ron Rich, Jim Boland, Vinnie Agvateesiri and Andre St. Louis without prejudice; IT IS HEREBY STIPULATED by and between Defendant and Plaintiff, through their respective attorneys, that Defendant's time in which to respond to Plaintiff's Complaint is extended by 15 days. The new date on or before which Defendant must respond to the Complaint is September 11, 2008. IT IS FURTHER STIPULATED by and between Defendant and Plaintiff that Defendants Glen F. Tilton, Barbara Liataud, Ron Rich, Jim Boland, Vinnie Agvateesiri and Andre St. Louis are dismissed from this lawsuit without prejudice. Dated: August 26, 2008 DLA PIPER US LLP

By:

/s/ Hope Anne Case HOPE ANNE CASE NORA CULVER Attorneys for Defendant UNITED AIR LINES, INC.

Dated: August 26, 2008

LAW OFFICES OF CHARLES J. KATZ By /s/ Charles J. Katz CHARLES J. KATZ Attorney for Plaintiff LARRY OILUND

Dated: August 26, 2008

LAW OFFICES OF ELLADENE LEE KATZ By /s/ Elladene Lee Katz ELLADENE LEE KATZ Attorney for Plaintiff LARRY OILUND

I, Hope Anne Case, am the ECF user whose ID and password are being used to file this STIPULATION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND TO DISMISS INDIVIDUAL DEFENDANTS. In compliance with General Order 45, X.B., I hereby attest that Charles J. Katz and Elladene Lee Katz have concurred in this filing. WEST\21501924.1 -2STIPULATION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND TO DISMISS INDIVIDUAL DEFENDANTS / CASE NO. C-08-04016 TEH