Free Stipulation - District Court of California - California

Case 4:07-cv-03944-SBA

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Filed 02/15/2008

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KATHRYN BURKETT DICKSON, State Bar No. 70636 DICKSON - ROSS LLP 1970 Broadway, Suite 1045 Oakland, CA 94612 Phone: 510-268-1999 Fax: 510-268-3627 E-mail: [email protected] Attorneys for Charging Party/Intervenor JANET STEGE UNTIED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

EQUAL EMPLOYMENT OPPORTUNITY ) COMMISSION, ) ) Plaintiff ) ) v. ) ) GEORGIA-PACIFIC LLC, ) ) Defendant. ) ) ____________________________________ )

CIVIL ACTION NO. C-07-3944 (SBA) STIPULATION TO CONTINUE HEARING DATE ON CHARGING PARTY JANET STEGE'S MOTION TO INTERVENE Date: Time: Courtroom: Judge: March 4, 2008 1:00 p.m. 3, 3rd Fl. (Oakland) Hon. Saundra B. Armstrong

The parties and Charging Party/Intervenor, through their undersigned counsel, hereby stipulate as follows: 1. Charging Party Janet Stege's Motion to Intervene, is currently scheduled for

hearing on March 4, 2008. Defendant has filed its opposition papers. 2. Counsel for Charging Party/Intervenor, Kathryn Dickson, is currently in trial in a

matter before Magistrate Judge Richard Seeborg: Grimes v. UPS, Case No. C-05-1824 (RS). Judge Seeborg and the parties in the Grimes matter anticipate that the presentation of evidence will be completed the week of February 18, 2008, that closing argument will given on February 25, 2008, and that the jury will begin deliberations later that day. 3. Defendant in this matter has filed a 22-page brief, and several declarations, in

opposition to Charging Party/Intervenor's Motion to Intervene. Charging Party/Intervenor's
Stipulation to Continue Hearing Date Civil Action No. C-07-3944 (SBA)

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reply brief is currently due on February 19, 2008. Given Ms. Dickson's trial schedule in the Grimes matter, she is simply unable to prepare and file a reply brief by the February 19th due date. 4. For the foregoing reasons, and to enable Charging Party/Intervenor sufficient

time to review and respond to Defendant's opposition, the parties hereby stipulate that the hearing date on the Motion to Intervene, currently set for March 4, 2008, be continued to April 1, 2008, the first hearing date available on the Court's calendar on which counsel for all parties are available, and that the due date for Charging Party/Intervenor's reply brief be continued to March 18, 2008, accordingly. 5. The parties also stipulate that Defendant may supplement its opposition papers,

on or before March 11, 2008, by submitting documents reflecting the EEOC's correspondence with Charging Party Janet Stege regarding the EEOC's determination, on or around June 9, 2005, that efforts to conciliate with Ms. Stege's employer had been unsuccessful. IT IS SO STIPULATED.

Dated: February 14, 2008 By:

DICKSON - ROSS LLP /s/ Kathryn Burkett Dickson KATHRYN BURKETT DICKSON Attorneys for Charging Party/Intervenor JANET STEGE LITTLER MENDELSON

Dated: February 14, 2008

By:

/s/ Joshua D. Kienitz JOSHUA D. KIENITZ Attorneys for Defendant GEORGIA-PACIFIC LLC

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Stipulation to Continue Hearing Date Civil Action No. C-07-3944 (SBA)

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Dated: February 14, 2008

U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

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Stipulation to Continue Hearing Date Civil Action No. C-07-3944 (SBA)

/s/ Linda Ordonio-Dixon LINDA ORDONIO-DIXON Attorneys for Plaintiff EEOC

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