Pfrommer et al v. R&D Media North Americas B.V. et al

Filing 23

STIPULATION and ORDER to Continue Hearing on Plaintiffs' Motion to Remand and to Continue Initial Scheduling Conference signed by Magistrate Judge Gary S. Austin on 11/6/2009. Motion Hearing RESET for 1/15/2010 at 09:30 AM in Courtroom 10 (GSA) before Magistrate Judge Gary S. Austin; Initial Scheduling Conference RESET for 3/12/2010 at 09:30 AM in Courtroom 10 (GSA) before Magistrate Judge Gary S. Austin. (Esteves, C)

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Robert M. Bodzin, State Bar No. 201327 Derek H. Lim, State Bar No. 209496 Kevin M. Larson, State Bar No. 245324 BURNHAM BROWN A Professional Law Corporation P.O. Box 119 Oakland, California 94604 --1901 Harrison Street, 11th Floor Oakland, California 94612 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] Attorneys for Defendant R&D MEDIA NORTH AMERICAS B.V. d/b/a GLOMOBI UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION WILLIAM PFROMMER and MICHAEL WATSON, individually and on behalf of a class of similarly situated individuals Plaintiffs, v. R&D MEDIA NORTH AMERICAS B.V. D/B/A GLOMOBI, a Dutch company, MBLOX, INC., a Delaware corporation, Defendants. Action No. 1:09-cv-01442-LJO-GSA [Stanislaus County Superior Court Action No. 636593] ORDER REGARDING STIPULATION TO CONTINUE HEARING ON PLAINTIFFS' MOTION TO REMAND AND TO CONTINUE INITIAL SCHEDULING CONFERENCE Date: Time: Judge: December 4, 2009 9:30 a.m. Magistrate Judge Gary S. Austin

Complaint Filed: January 15, 2009 Trial Date: None Set Plaintiffs WILLIAM PFROMMER and MICHAEL WATSON (collectively "Plaintiffs") and Defendants MBLOX, INC. ("Defendant" or "mBlox") and R&D MEDIA NORTH AMERICA B.V. d/b/a GLOMOBI ("Defendant" or "R&D") hereby stipulate and respectfully request that the Court continue the hearing for Plaintiffs' Motion to Remand presently set for hearing before Magistrate Judge Gary S. Austin on December 4, 2009 and the Case Management Conference and Initial Scheduling Conference currently set for February 18, 2010. In support of this Stipulation, the Parties state as follows:
1 STIPULATION TO CONTINUE HEARING ON PLAINTIFFS' MOTION TO REMAND AND CASE MANAGEMENT CONF. Case No. 1:09-cv-01442-LJO-GSA

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1.

Plaintiffs originally filed this action in the Stanislaus County Superior Court on

January 15, 2009. Plaintiffs filed a First Amended Complaint on June 8, 2009. 2. This action was removed from Stanislaus County Superior Court to this court by

Defendant R&D MEDIA NORTH AMERICA B.V. d/b/a GLOMOBI on August 17, 2009. 3. Good cause exists to continue the hearing dates because counsel for R&D was set

for trial in another matter on October 23, 2009, but said trial has now been continued to November 17, 2009. NOW, THEREFORE, the Parties hereby stipulate and agree that, with the Court's approval: 1. The hearing on Plaintiff's Motion to Remand is continued from December 4, 2009 to January 15, 2010, at 9:30 a.m., before Magistrate Judge Gary S. Austin, and 2. The Initial Scheduling Conference currently set for February 18, 2010 is continued to March 12, 2010. 3. All other deadlines related to the hearings are continued accordingly. KAMBEREDELSON, LLC By: /s/ Myles McGuire as authorized 11/6/09 Alan Himmelfarb Myles McGuire Attorney for Plaintiffs William Pfrommer and Michael Watson

Dated: November 6, 2009

Dated: November 6, 2009

WILDMAN HARROLD ALLEN & DIXON, LLP By: /s/ Chung-Han Lee as authorized 11/6/09 Chung-Han Lee Attorney for Defendant mBlox, Inc.

2 STIPULATION TO CONTINUE HEARING ON PLAINTIFFS' MOTION TO REMAND AND CASE MANAGEMENT CONF.

Case No. 1:09-cv-01442-LJO-GSA

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Dated: November 6, 2009

BURNHAM BROWN By: /s/ Kevin Larson 11/6/09 Kevin Larson Attorney for Defendant R&D Media North America B.V. ORDER

IT IS SO ORDERED. Dated: November 6, 2009.

/s/ Gary S. Austin HON. GARY S. AUSTIN United States Magistrate Judge

975668

3 STIPULATION TO CONTINUE HEARING ON PLAINTIFFS' MOTION TO REMAND AND CASE MANAGEMENT CONF.

Case No. 1:09-cv-01442-LJO-GSA