Brave New Films 501 (C)(4) v. Weiner et al

Filing 38

STIPULATION re 24 MOTION to Dismiss STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING by Michael Weiner, Original Talk Radio Network Inc., Brave New Films 501 (C)(4). (Pierce, Sheila) (Filed on 2/19/2009)

Brave New Films 501 (C)(4) v. Weiner et al Doc. 38 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 Anthony T. Falzone (SBN 190845) Julie A. Ahrens (SBN 230170) Christopher K. Ridder (SBN 218691) STANFORD LAW SCHOOL CENTER FOR INTERNET AND SOCIETY 559 Nathan Abbott Way Stanford, California 94305-8610 Telephone: (650) 736-9050 Facsimile: (650) 723-4426 E-mail: falzone@stanford.edu William F. Abrams (SBN 88805) Sheila M. Pierce (SBN 232610) BINGHAM MCCUTCHEN LLP 1900 University Avenue East Palo Alto, CA 94303-2223 Telephone: 650.849.4400 Facsimile: 650.849.4800 E-mail: william.abrams@bingham.com Attorneys for Plaintiff BRAVE NEW FILMS 501(c)(4) Benjamin Aaron Shapiro (SBN 254456) 12330 Magnolia Boulevard, No. 114 Valley Village, CA 91607 Telephone: (818) 620-0137 Attorney for Defendants MICHAEL WEINER aka MICHAEL SAVAGE, and ORIGINAL TALK RADIO NETWORK, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION BRAVE NEW FILMS 501(C)(4), v. Plaintiff, No. CV 08-04703 SI STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING Date: March 13, 2009 Time: 9:00 a.m. Location: Courtroom 10 Honorable Susan Illston MICHAEL WEINER aka MICHAEL SAVAGE, and ORIGINAL TALK RADIO NETWORK, INC., Defendants. CV 08-04703 SI STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING Dockets.Justia.com 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 follows: 13, 2009; following: Pursuant Civil L.R. 6-1(a) and Civil L.R. 7-7(a), the parties stipulate to the WHEREAS, on October 10, 2008, this action for declaratory judgment and damages was commenced in the United States District Court, Northern District of California; WHEREAS, on January 11, 2009, defendant Michael Weiner aka Michael Savage ("Savage") filed a Motion To Dismiss, Docket Number 24; WHEREAS, the hearing on Savage's Motion To Dismiss is calendared for March WHEREAS, for efficiency, Brave New Films requested, and Savage agreed, to continue the hearing on Savage's Motion until April 3, 2009, the date of the Summary Judgment hearings and the Case Management Conference; WHEREAS, the parties have not previously stipulated to continue the hearing. NOW THEREFORE, it is STIPULATED, AGREED AND ORDERED as The hearing on defendant Michael Weiner aka Michael Savage's Motion To Dismiss will be continued to April 3, 2009 at a time to be determined by the Court. DATED: February 19, 2009 Bingham McCutchen LLP By: /s/ William F. Abrams William F. Abrams Attorneys for Plaintiff BRAVE NEW FILMS 2 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING CV 08-04703 SI 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 DATED: February 19, 2009 By: /s/ Benjamin Aaron Shapiro Benjamin Aaron Shapiro Attorneys for Defendant Michael Weiner aka Michael Savage and Original Talk Radio Network, Inc. PURSUANT TO STIPULATION, IT IS SO ORDERED. DATED:_________________ By: _______________________________ THE HONORABLE SUSAN ILLSTON UNITED STATES DISTRICT JUDGE 3 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING CV 08-04703 SI 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 CERTIFICATION BY SHEILA M. PIERCE PURSUANT TO GENERAL ORDER NO. 45, SECTION X. RE E-FILING ON BEHALF OF MULTIPLE SIGNATORIES 1. I am a lawyer licensed to practice law in the State of California, and am an associate in the law firm of Bingham McCutchen LLP, counsel for Plaintiff Brave New Films 501(c)(4). The statements herein are made on my personal knowledge, and if called as a witness I could and would testify thereto. 2. The above e-filed document contains multiple signatures. I declare that concurrence has been obtained from each of the other signatories to file this jointly prepared document with the Court. Pursuant to General Rule No. 45, I shall maintain records to support this concurrence for subsequent production for the Court if so ordered, or for inspection upon request by a party until one year after final resolution of the action (including appeal, if any). I declare under penalty of perjury under the laws of the United States of America and the State of California that the foregoing is true and correct on February 19, 2009 in East Palo Alto, California. /s/ Sheila M. Pierce Sheila M. Pierce 4 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING CV 08-04703 SI