Hepting et al v. AT&T Corp. et al

Filing 224

EVIDENTIAY OBJECTIONS to Declaration of James W. Russell in Support of Motion of Defendant AT&T Corp. to Compel Return of Confidential Documents by Gregory Hicks, Erik Knutzen, Tash Hepting, Benson B. Roe, Carolyn Jewel. FILED UNDER SEAL (gba, COURT STAFF) (Filed on 4/17/2006)

Case3:06-cv-00672-VRW Document271

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HOWARD MOORE, JR.(SBN 55228) CHARLES STEPHEN RALSTON (SBN 34111) Moore and Moore Law Offices of Charles Stephen Ralston 445 Bellevue Avenue, Second Floor 2421 Valley Street Oakland, California 94610-4924 Berkeley, California 94702 Telephone: [phone] Telephone: [phone] Facsimile: [phone] Facsimile: [phone] Email: [e-mail] Email: [e-mail] Attorneys for Plaintiff LAVON JONES, JR. JEROME SCHREIBSTEIN (SBN 154051) STEPHEN K. ROBINSON (SBN 217898) PAYNE & FEARS LLP One Embarcadero Center, Suite 2300 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant BAYER HEALTHCARE LLC UNITED STATES DISTRICT COURT

11 NOR THE RN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 15 Plaintiff, 16 vs. 17 18 19 20 21 WHEREAS, plaintiff's opposition to defendant's motion for summary judgment is 22 currently due on December 1, 2006: 23 WHEREAS, defendant's reply thereto is currently due on December 15, 2006; 24 WHEREAS, the hearing for the motion for summary judgment is currently set for January 25 26, 2007; 26 WHEREAS, counsel for plaintiff, Charles Stephen Ralston was required to complete and 27 28
S t ip u l a ti o n and [Proposed] Ord e r Re g a r d i n g Summary Jud g m e n t M o t i o n Schedule J o n e s v. Bayer Healthcare C-03-05531 JSW

LAVON JONES, JR.

) ) ) ) ) )

Case No. C-03-05531-JSW

STIPULATION AND [PROPOSED] ORDER REGARDING SUMMARY JUDGMENT MOTION SCHEDULE DATE: TIME: COURTROOM: January 26, 2007 9:00 a.m. 2, 17TH Floor

) ) ) ) Defendant. ) ____________________________________) BAYER HEALTHCARE, LLC

Honorable Jeffrey S. White

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file the Reply Brief in the Ninth Circuit in the case of Stevens v. County of San Mateo, No. 0615634, by November 27, 2006, and must complete and file the Opening Brief in the Ninth Circuit in the case of Woods v. Bayer Healthcare, No. 06-16529, by December 4, 2006, and counsel for plaintiff Howard Moore, Jr., was required to complete and file the Reply Brief in the Ninth Circuit in the case of Christian v. Lucille Packard Children''s Hospital by November 27, 2006, and is scheduled to begin trial in another case in the Northern District of California during the week of November 27, 2006, they will not be able to complete the review of the extensive record in this case and to complete the opposition to the Motion for Summary Judgment by the current due date. WHEREAS, the stipulated dates set out below will not require any change in the hearing date of January 26, 2007, and are fully consistent with the time requirements of Local Rule 7-3(a) and (c), as well as Local Rule 7-7(d), in that the opposition will be due 42 days before the date of the hearing and the reply thereto 14 days before the date of the hearing; WHEREAS, although plaintiff, on the one hand, and defendant, on the other hand, are collectively adverse, they agree through their respective counsel and stipulate as follows: 1. 2. Plaintiff's opposition will now be due December 15, 2006; and Defendant's reply thereto will now be due January 12, 2007.

IT IS SO STIPULATED. DATED: November 28, 2006 By: MOORE & MOORE s/Howard Moore, Jr. HOWARD MOORE, JR. Attorney for Plaintiff LAVON JONES, JR. s/Charles Stephen Ralston CHARLES STEPHEN RALSTON Attorney for Plaintiff LAVON JONES, JR.

DATED: November 28, 2006 25 26 27 28

By:

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DATED: November 28, 2006

PAYNE & FEARS LLP By: s/Jerome Schreibstein JEROME SCHREIBSTEIN STEPHEN K. ROBINSON Attorneys for Defendant BAYER HEALTHCARE LLC

3 4 5 6 IT IS SO ORDERED. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: _________________, 2006

_________________________________ Honorable Jeffrey S. White UNITED STATES DISTRICT JUDGE NOR THE RN DISTRICT OF CALIFORNIA

S t ip u l a ti o n and [Proposed] Ord e r Re g a r d i n g Summary Jud g m e n t M o t i o n Schedule J o n e s v. Bayer Healthcare C-03-05531 JSW

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