Barnes v. AT&T Pension Benefit Plan-NonBargained Program

Filing 408

STIPULATION AND ORDER re 407 STIPULATION WITH PROPOSED ORDER re 406 Order on Motion for Leave to File, Order on Motion for Miscellaneous Relief, filed by Quiller Barnes. Signed by Judge Edward M. Chen on 10/18/13. (bpf, COURT STAFF) (Filed on 10/18/2013)

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COHEN MILSTEIN SELLERS & TOLL PLLC
R. Joseph Barton (CA State Bar No. 212340)
Email: [e-mail]
Bruce F. Rinaldi (CA State Bar No. 55133)
Email: [e-mail]
1100 New York Avenue, N.W.
West Tower, STE 500
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]

Attorneys for Plaintiff & the Class
QUILLER BARNES

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PAUL HASTINGS LLP
Patrick W. Shea (NY State Bar No. 4587176), Pro Hac Vice
Email: [e-mail]
75 East 55th Street
New York, NY 10022
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant

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AT&T PENSION BENEFIT PLAN –
NONBARGAINED PROGRAM
[Additional counsel listed on next page]

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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QUILLER BARNES,
Plaintiff,
vs.
AT&T PENSION BENEFIT PLAN –
NONBARGAINED PROGRAM,
Defendant.

CASE NO. 08-04058 EMC
JOINT STIPULATION AND
[PROPOSED] ORDER EXTENDING
BRIEFING SCHEDULE ON
DEFENDANT’S MOTION FOR
RECONSIDERATION OF
PLAINTIFF’S AWARD OF NONTAXABLE EXPENSES

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Case No. 08-04058 EMC

JOINT STIP. RE BRIEFING SCHEDULE ON FEE
MOTION; [PROPOSED] ORDER

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SPRINGER & ROBERTS LLP
Michelle L. Roberts (CA State Bar No. 239092)
Email: [e-mail]
410 – 12th Street, Suite 325
Oakland, CA 94607
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff & the Class

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QUILLER BARNES

PAUL HASTINGS LLP
Stephen H. Harris (CA State Bar No. 184608)
Email: [e-mail]
M’Alyssa C. Mecenas (CA State Bar No. 272075)
Email: [e-mail]
515 South Flower Street, 25th Floor
Los Angeles, CA 90071
Telephone: [phone]
Facsimile: [phone]

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PAUL HASTINGS LLP
Regan A.W. Herald (CA State Bar No. 251879)
875 15th Street, N.W.
Washington, DC 20005
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Defendant

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AT&T PENSION BENEFIT PLAN –
NONBARGAINED PROGRAM

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Case No. 08-04058 EMC

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JOINT STIP. RE BRIEFING ON D’S MOT FOR
RECONSIDERATION; [PROPOSED] ORDER

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Plaintiff Quiller Barnes and Defendant AT&T Pension Benefit Plan – Nonbargained

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Program (collectively referred to as the “Parties”), acting through their respective counsel of record,

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hereby stipulate as follows:

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WHEREAS, on October 10, 2013, the Court issued an order disposing of the motions at

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Docket Nos. 392, 398, and 405 (D.E. #406) and the Court encouraged the Parties to meet and

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confer to see if they could reach agreement on costs given the Court’s rulings in the Order on fees;

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WHEREAS, counsel for the Parties have met and conferred in good faith, believe they are

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close to reaching a resolution, and believe that the Parties would benefit from additional time as they

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attempt to resolve the cost issue without Court intervention;

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IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES that in order to
avoid unnecessary briefing the Parties request that the Court extend the deadlines as follows:
1. The deadline for Plaintiff to file a response to Defendant’s Motion for

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Reconsideration (D.E. #392) is extended from October 17, 2013 to October 24,

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2013.

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2. The deadline for Defendant to file a reply to Plaintiff’s response is extended from
October 24, 2013 to October 31, 2013.

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DATED: October 17, 2013

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/s/ Michelle L. Roberts
MICHELLE L. ROBERTS

Attorneys for Plaintiff & the Class
Quiller Barnes

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By:

DATED: October 17, 2013

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By:

/s/ Stephen H. Harris
STEPHEN H. HARRIS

Attorneys for Defendant
AT&T Pension Benefit Plan - Nonbargained Program

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Case No. 08-04058 EMC

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JOINT STIP. RE BRIEFING ON D’S MOT FOR
RECONSIDERATION; [PROPOSED] ORDER

SIGNATURE ATTESTATION

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I, Michelle L. Roberts, hereby attest that concurrence in the filing of the document has been
obtained from the other signatory on this document.

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DATED: October 17, 2013

By:

/s/ Michelle L. Roberts
MICHELLE L. ROBERTS

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

HON. EDWARD M. CHEN
United States District Court

UNIT
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By:

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October 18

DATED: _________________, 2013

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Case No. 08-04058 EMC

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JOINT STIP. RE BRIEFING ON D’S MOT FOR
RECONSIDERATION; [PROPOSED] ORDER