Parrish et al v. National Football League Players Incorporated

Filing 46

STIPULATION re 45 Letter for Continuance of (1) Case Management Conference, (2) Plaintiffs' Motion to Appoint Manatt as Interim Counsel; (3) Defendant's Motions for (a) Motion to Transfer Venue; (b) Motion for Judgment on the Pleadings; and (c) Motion for Sanctions by National Football League Players Incorporated. (O'Kelly, Eamon) (Filed on 4/13/2007)

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Parrish et al v. National Football League Players Incorporated Doc. 46 Case 3:07-cv-00943-WHA Document 46 Filed 04/13/2007 Page 1 of 3 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 Jeannine Yoo Sano (Bar No. 174190) jsano@deweyballantine.com DEWEY BALLANTINE LLP 1950 University Avenue, Suite 500 East Palo Alto, CA 94303 Tel: (650) 845-7000; Fax: (650) 845-7333 Jeffrey L. Kessler (pro hac vice) jkessler@deweyballantine.com David G. Feher (pro hac vice) dfeher@deweyballantine.com Eamon O'Kelly (pro hac vice) eokelly@deweyballantine.com DEWEY BALLANTINE LLP 1301 Avenue of the Americas New York, NY 10019-6092 Tel: (212) 259-8000; Fax: (212) 259-6333 Kenneth L. Steinthal (pro hac vice pending) kenneth.steinthal@weil.com Joseph R. Wetzel (238008) joseph.wetzel@weil.com Weil, Gotshal & Manges 201 Redwood Shores Parkway Redwood Shores, CA 94065 Tel: (650) 802-3000; Fax: (650) 802-3100 Bruce S. Meyer (pro hac vice pending) bruce.meyer@weil.com Weil, Gotshal & Manges LLP 767 Fifth Avenue New York, NY 10153 Tel: (212) 310-8000; Fax: (212) 310-8007 Attorneys for Defendant National Football League Players Incorporated d/b/a Players Inc., a Virginia Corporation UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY, WALTER ROBERTS III on behalf of themselves and all others similarly situated, Plaintiffs, v. NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a/ PLAYERS INC., a Virginia Corporation, Defendant. Case No. C 07 00943 WHA STIPULATION FOR CONTINUANCE OF (1) CASE MANAGEMENT CONFERENCE; (2) PLAINTIFF'S MOTION TO APPOINT MANATT AS INTERIM COUNSEL; (3) DEFENDANT'S MOTIONS FOR (a) MOTION TO TRANSFER VENUE; (b) MOTION FOR JUDGMENT ON THE PLEADINGS; AND (c) MOTION FOR SANCTIONS Judge: Honorable William H. Alsup Case No. C 07-00943 WHA Stipulation for Continuance Dockets.Justia.com Case 3:07-cv-00943-WHA Document 46 Filed 04/13/2007 Page 2 of 3 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 12(c); and WHEREAS Plaintiffs Bernard Paul Parrish, Herbert Anthony Adderley and Walter Roberts III, on behalf of themselves and all others similarly situated (hereinafter "Plaintiffs") filed a Motion to Appoint Manatt, Phelps & Phillips LLP as Interim Class Counsel and scheduled same for hearing on May 3, 2007; WHEREAS Defendants National Football League Players Incorporated d/b/a Players, Inc., a Virginia Corporation (hereinafter "Defendant") filed three motions: (a) (b) Motion to Transfer Venue Pursuant to 28 U.S.C. 1040(a); Motion for Judgment on the Pleadings Pursuant to Fed. R. Civ. P. 12(c); (c) Motion for Sanctions Pursuant to Fed. R. Civ. P. 11, 28 U.S.C. 1927, and the Court's Inherent Powers and scheduled same for hearing on May 17, 2007; and WHEREAS the Court, by Order dated March 2, 2007, scheduled an Initial Case Management Conference for May 17, 2007, at 11:00 a.m.; and WHEREAS the requested continuance would foster judicial economy and efficiency and also save the parties the time and expense that they would otherwise expend if they had to participate in two separate hearings, further promoting the efficient judicial administration of this action; and WHEREAS the parties have met and conferred regarding a mutually agreeable date for the hearing of both Plaintiffs' and Defendant's respective motions, and the Initial Case Management Conference; IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES HERETO, through their respective counsel, that: 1. Counsel ; 2. 3. Defendant's Motion to Transfer Venue Pursuant to 28 U.S.C. 1040(a); Defendant's Motion for Judgment on the Pleadings Pursuant to Fed. R. Civ. P. Plaintiffs' Motion to Appoint Manatt, Phelps & Phillips LLP as Interim Class Case No. C 07-00943 WHA Stipulation for Continuance Case 3:07-cv-00943-WHA Document 46 Filed 04/13/2007 Page 3 of 3 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 4. Defendant's Motion for Sanctions Pursuant to Fed. R. Civ. P. 11, 28 U.S.C. 1927, and the Court's Inherent Powers; and 5. Initial Case Management Conference; shall all be continued for hearing to either May 31, 2007 or June 14, 2007, at the Court's convenience. IT IS FURTHER STIPULATED that the respective motions shall be heard by oral argument at 8:00 a.m., and the Initial Case Management Conference shall be heard at 11:00 a.m. IT IS FURTHER STIPULATED that any oppositions, replies, and/or case management statement shall be filed in accordance with local rules. Dated: April 13, 2007 DEWEY BALLANTINE LLP By_____________________________________ Eamon O'Kelly Attorneys for Defendant Players Inc. Dated: April 13, 2007 MANATT, PHELPS & PHILLIPS LLP By______________________________________ Ryan S. Hilbert Attorneys for Plaintiffs Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, I attest under penalty of perjury that concurrence in the filing of the document has been obtained from Ryan S. Hilbert. Dated: April 13, 2007 DEWEY BALLANTINE LLP By_____________________________________ Eamon O'Kelly Attorneys for Defendant Players Inc. Case No. C 07-00943 WHA Stipulation for Continuance

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