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ROBERTA L. STEELE, SBN 188198 (CA) MARCIA L. MITCHELL, SBN 18122 (WA) JAMES H. BAKER JR, SBN 291836 (CA) KENA C. CADOR, SBN 321094 (CA) U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office 450 Golden Gate Ave., 5th Floor West P.O. Box 36025 San Francisco, CA 94102 Telephone No. (650) 684-0933 Fax No. (415) 522-3425 kena.cador@eeoc.gov Attorneys for Plaintiff EEOC
THOMAS E. HILL, SBN 100861 thomas.hill@hklaw.com CHRISTINA T. TELLADO, SBN 298597 christina.tellado@hklaw.com HOLLAND & KNIGHT, LLP 400 South Hope Street, 8th Floor Los Angeles, California 90071 Telephone: (213) 896-2400 Facsimile: (213) 896-2450 Attorneys for Defendant Tesla
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
U.S. EQUAL EMPLOYMENT
OPPORTUNITY COMMISSION,
Plaintiff,
vs.
Case No.: 3:23-cv-04984-JSC STIPULATION AND [PROPOSED] ORDER ENLARGING BRIEFING SCHEDU FOR TESLA’S MOTION TO DISMISS AND RESETTING HEARING DATE
TESLA, INC.,
Defendant.
Plaintiff U.S. Equal Employment Opportunity Commission (EEOC) and Defendant Tesla,
Inc. (Tesla) (collectively, the Parties) jointly submit this request in accordance with Local Rules 6-2
and 7-12 for the Court to enlarge the briefing schedule for the opposition and reply deadlines for
Tesla’s Motion to Dismiss the Complaint (ECF 27) and resetting the hearing date for this motion.
STIPULATION AND [PROPOSED] ORDER TO ENLARGE BRIEFING SCHEDULING AND CONTINUE RELATED HEARING.
Case No.: 3:23-cv-04984-JSC
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Plaintiff EEOC filed the Complaint in this matter on September 28, 2023. (ECF 1) On
December 18, 2023, Defendant Tesla filed a Notice of Motion and Motion to Stay All Proceedings
and requested a hearing on February 1, 2024. (ECF 22) The current deadlines for the Parties to
submit an opposition and a reply there to are January 3, 2024, and January 10, 2024, respectively
(ECF 22-A). On December 26, 2023, Defendant Tesla filed a Notice of Motion and Motion to
Dismiss and requested a hearing on February 8, 2024. (ECF 27) The current deadlines for the Parties
to submit an opposition and a reply thereto are January 9, 2024, and January 16, 2024, respectively
(ECF 27-A).
The Parties seek modest additional time to prepare their respective briefings for the Motion
to Dismiss, the schedule for which has fallen over the holidays and overlaps with the Parties’
opposition and reply for the Motion to Stay. Extending the time to complete the briefing and hear
Tesla’s Motion to Dismiss, a date which was noticed by Tesla, will not otherwise disrupt any other
deadlines in the case. The only prior time modification requested and received by the Parties was to
vacate the initial case management deadlines until after the Court rules on Tesla’s Motion to Stay All
Proceedings (ECF 23, 24).
STIPULATION
WHEREAS, the Parties believe that good cause exists to enlarge the briefing schedule and
continue the related hearing date for Tesla’s Motion to Dismiss, as the briefing schedule overlaps
with briefing on the Motion to Stay, the additional requested time is modest, and the enlargement
will not disrupt any other deadlines in the case;
WHEREAS, the Parties have requested only one other continuance to vacate the initial case
deadlines and deadline to meet and confer pursuant to Rule 26(f) until the Court rules on the Motion
to Stay.
THEREFORE, it is hereby stipulated and agreed that, subject to Court approval, the briefing
deadlines for Tesla’s Motion to Dismiss will be enlarged as follows: The deadline for the EEOC to
oppose this Motion will be January 30, 2024, and the deadline for Tesla to reply to the opposition
will be February 6, 2024. Also, subject to Court approval, the Parties’ request that the hearing on this
Motion be held on February 22, 2024.
STIPULATION AND [PROPOSED] ORDER TO
ENLARGE BRIEFING SCHEDULING AND CONTINUE
RELATED HEARING.
Case No.: 3:23-cv-04984-JSC
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IT IS SO STIPULATED.
Respectfully submitted,
DATED this 29th of December, 2023.
ROBERTA STEELE
Regional Attorney
KARLA GILBRIDE
General Counsel
MARCIA L. MITCHELL
Assistant Regional Trial Attorney
CHRISTOPHER LAGE
Deputy General Counsel
JAMES H. BAKER
Senior Trial Attorney
Office of the General Counsel 131 M Street, N.E.
Washington, D.C. 20507
KENA C. CADOR
Trial Attorney
BY:
/s/ James H. Baker James H. Baker U.S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION San Francisco District Office 450 Golden Gate Ave., 5th Floor West P.O. Box 36025 San Francisco, CA 94102 Telephone (650) 684-0933 james.baker@eeoc.gov Attorneys for Plaintiff EEOC
By:
/s/ Thomas E. Hill .
THOMAS E. HILL, ESQ.
CHRISTINA TELLADO, ESQ
HOLLAND & KNIGHT, LLP
400 South Hope Street, 8th Floor Los Angeles, California 90071 Telephone: (213) 896-2400 Facsimile: (213) 896-2450 christina.tellado@hklaw.com Attorneys for Defendant Tesla, Inc.
STIPULATION AND [PROPOSED] ORDER TO ENLARGE BRIEFING SCHEDULING AND CONTINUE RELATED HEARING.
Case No.: 3:23-cv-04984-JSC
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LOCAL RULE 5-1(I)(3) ATTESTATION
I, James H. Baker, am the ECF User whose ID and password are being used to file the
foregoing document. In compliance with Local Rule 5-1(i)(3), I hereby attest that counsel for
Defendant concurred in this filing on December 29, 2023.
Dated: December 29, 2023
BY:
/s/ James H. Baker JAMES H. BAKER
[PROPOSED] ORDER
Based on the foregoing stipulation of the Plaintiff U.S. Equal Employment Opportunity Commission and Defendant Tesla, Inc., IT IS HEREBY ORDERED THAT:
1. The hearing on Tesla’s Motion to Dismiss the Complaint [ECF 27] is reset for 2/22/2024 10:00 AM in San Francisco, Courtroom 08, 19th Floor.
2. Responses are due by 1/30/2024. Replies are due by 2/6/2024. PURSUANT TO STIPULATION, IT IS SO ORDERED.
Dated: January 2, 2024
HON.
JACQUELINE
CORLEY
ON. JA
ACQ
C UELINE SCOTT CORL
LE EY Y United States District nit i ed S tates Dist trict Court Judge
STIPULATION AND [PROPOSED] ORDER TO
ENLARGE BRIEFING SCHEDULING AND CONTINUE RELATED HEARING.
Case No.: 3:23-cv-04984-JSC
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