5:26-cv-08106•Paczewski v. Agilent Technologies Inc. Health Plan
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-1- STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK 9180003.v2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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
-2- STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK 9180003.v2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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
-3- STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK 9180003.v2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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
-4- STIPULATION AND [PROPOSED] ORDER TO EXTEND ALL CASE DEADLINES; Case No: 5:26-cv-08106-SVK 9180003.v2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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
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