Paczewski v. Agilent Technologies Inc. Health Plan

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STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK
9180003.v2
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Trucker
  Huss
A Professional Corporation	
135 Main Street, 9
th Floor
San Francisco, California 94105
Clarissa A. Kang, No. 210660
Shuying Lin, No. 338710
TRUCKER  HUSS
A Professional Corporation
135 Main Street, 9th Floor
San Francisco, CA 94105
Telephone: (415) 788-3111
Facsimile: (415) 421-2017
E-mail: ckang@truckerhuss.com
slin@truckerhuss.com
Attorneys for Defendant
AGILENT TECHNOLOGIES INC.
HEALTH PLAN
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
RICHARD PACZEWSKI,
Plaintiff,
vs.
AGILENT TECHNOLOGIES INC.
HEALTH PLAN,
Defendant.
Case No. 5:26-cv-08106-SVK
STIPULATION AND [PROPOSED] ORDER
TO EXTEND ALL CASE DEADLINES
[L.R. 6-2, 7-12, 16-2(e)]
Complaint Filed: August 4, 2026
Trial Date: None Set
Pursuant to Civil Local Rules 6-2, 7-12, and 16-2(e), Defendant Agilent Technologies Inc.
Health Plan (“Defendant”) and Plaintiff Richard Paczewski (“Plaintiff”) (together, the “Parties”), by
and through their undersigned counsel, hereby stipulate and agree as follows and jointly request that
the Court enter the Order below approving this stipulation:
WHEREAS, Plaintiff filed the Complaint in this action on August 4, 2026 (Dkt. 1);
WHEREAS, on August 18, 2026, Defendant executed and returned a waiver of service of
summons under Federal Rule of Civil Procedure 4(d) (Dkt. 7), which Plaintiff requested on August
17, 2026;
WHEREAS, Defendant’s response to the Complaint is currently due on or before October
16, 2026;
WHEREAS, the Court issued an Order Setting Initial Case Management Conference and
ADR Deadlines (the “Order”) on August 5, 2026 (Dkt. 6), which set the Initial Case Management
Case 5:26-cv-08106-SVK Document 9 Filed 10/14/26 Page 1 of 4

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STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK
9180003.v2
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Trucker
  Huss
A Professional Corporation	
135 Main Street, 9
th Floor
San Francisco, California 94105
Conference for November 3, 2026, at 9:30 a.m., and related ADR, initial disclosure, and Joint Case
Management Statement deadlines;
WHEREAS, the Parties have engaged in an informal exchange of information with the goal
of discussing potential early resolution of this action, and additional time will allow those
exchanges of information and discussions to continue;
WHEREAS, the Parties wish to avoid expending time and resources associated with briefing
a motion to dismiss should the Parties ultimately resolve this action;
WHEREAS, the Parties have agreed to extend Defendant’s deadline to respond to the
Complaint by 60 days, to December 15, 2026, and to continue the Initial Case Management
Conference to January 12, 2027 and correspondingly continue all related deadlines in the Order;
WHEREAS, as set forth in the accompanying Declaration of Clarissa A. Kang, there have
been no previous time modifications in this case, and the requested modifications will not affect any
other dates fixed by Court order, as no other such dates have been set;
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED between the Parties,
by and through their counsel of record, and the Parties respectfully request that the Court order case
deadlines are continued as follows1:
1 The Parties also stipulate to extend any and all other deadlines associated with the responsive
pleading or case management deadlines that are not expressly identified herein, consistent with the
timelines set forth in the applicable rules, as otherwise ordered by the Court, or, to the extent
permitted by Civil Local Rule 6-1(a), as otherwise agreed upon by the Parties.
Case 5:26-cv-08106-SVK Document 9 Filed 10/14/26 Page 2 of 4

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STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK
9180003.v2
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Trucker
  Huss
A Professional Corporation
	135 Main Street, 9
th Floor
San Francisco, California 94105
Case Management Event Current Deadline New Deadline
Defendant’s Response to
the Complaint
October 16, 2026 December 15, 2026
Deadline to file ADR
Certification
October 13, 2026 December 22, 2026
Deadline to meet and
confer re: initial
disclosures, early
settlement, ADR process
selection, and discovery
plan
October 13, 2026 December 22, 2026
Deadline to make initial
disclosures
October 27, 2026 January 5, 2027
Deadline to file Joint Case
Management Statement
October 27, 2026 January 5, 2027
Initial Case Management
Conference
November 3, 2026, at
9:30 a.m.
January 12, 2027, at 9:30
a.m. (or another date and
time convenient for the
Court)
IT IS SO STIPULATED.
Dated: October 9, 2026 TRUCKER  HUSS
By: /s/ Clarissa A. Kang
Clarissa A. Kang
Attorneys for Defendant
AGILENT TECHNOLOGIES INC. HEALTH
PLAN
Dated: October 9, 2026 GREEN HEALTH LAW, APC
By: /s/ Elizabeth K. Green
Elizabeth K. Green
Attorneys for Plaintiff
RICHARD PACZEWSKI
January 19, 2027
January 12, 2027
Case 5:26-cv-08106-SVK Document 9 Filed 10/14/26 Page 3 of 4

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STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK
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Trucker
  Huss
A Professional Corporation
	135 Main Street, 9
th Floor
San Francisco, California 94105
I attest that all other signatories listed, and on whose behalf this filing is submitted, concur
in the filing’s content and have authorized the filing.
DATED: October 9, 2026 TRUCKER  HUSS
By: /s/ Clarissa A. Kang
Clarissa A. Kang
Attorneys for Defendant
AGILENT TECHNOLOGIES INC. HEALTH
PLAN
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
By:
HON. SUSAN VAN KEULEN
UNITED STATES MAGISTRATE JUDGE
Dated: October 14, 2026
Case 5:26-cv-08106-SVK Document 9 Filed 10/14/26 Page 4 of 4