Ambroff et al v. American Medical Systems, Inc.

Filing 43

STIPULATION AND ORDER re 42 Stipulation filed by American Medical Systems, Inc.. Signed by Judge James Larson on 10/20/09. (wh, COURT STAFF) (Filed on 10/20/2009)

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Case3:08-cv-04289-JL Document42 Filed10/19/09 Page1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 KEN M. MARKOWITZ (SBN 104674) SAMANTHA D. HILTON (SBN 215585) KENNEY & MARKOWITZ L.L.P. 255 California Street, Suite 1300 San Francisco, CA 94111 Tel: (415) 397-3100 Fax: (415) 397-3170 Email: kmarkowitz@kennmark.com shilton@kennmark.com Attorneys for Defendant AMERICAN MEDICAL SYSTEMS, INC. DAN JOHNSON (Pro Hac Vice) AMERICAN MEDICAL SYSTEMS, INC. 10700 Bren Road West Minnetonka, MN 55343 Tel: (952) 933-4666 Fax: (952) 930-6157 Email: Dan.Johnson@AmericanMedicalSystems.com Attorneys for Defendant AMERICAN MEDICAL SYSTEMS, INC. UNITED STATES DISTRICT COURT 14 NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO ­ ECF PROGRAM 16 17 18 19 20 21 22 23 24 25 This Stipulation is entered into between Plaintiffs, Ellen Ambroff and Terry Ambroff, by 26 Kenney Markowitz L.L.P. & ELLEN AMBROFF and TERRY AMBROFF, Plaintiffs, v. AMERICAN MEDICAL SYSTEMS, INC., and DOES ONE through TWENTY-FIVE, inclusive, Defendants. CASE NO. C08-04289 JL STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT AND PRETRIAL ORDER DATED 6/29/09__________ Civil L.R. 7-12 and through their counsel of record, Hersh and Hersh, a professional corporation, and Defendant, 27 American Medical Systems, Inc., by and through its counsel of record, Kenney & Markowitz, 28 L.L.P. The parties stipulate as follows: {30115.302053 0139269.DOC} -1STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT AND PRETRIAL ORDER DATED 6/29/09; CASE NO: C08-04289 JL Case3:08-cv-04289-JL Document42 Filed10/19/09 Page2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 1. Based upon the parties Joint Case Management Statement and discussion at the June 24, 2009 Case Management Conference, on June 29, 2009, the Court entered its Case Management and Pretrial Order scheduling various dates in this matter. 2. During July, 2009, the Court's clerk contacted counsel for AMS to inform them that the date chosen as the last day to hear dispositive motions was not suitable and that parties should stipulate to another date. The Court suggested September 30, 2010 as the last day to hear dispositive motions. 3. The parties stipulate and respectfully request that the Court order September 30, 2010 as the last day to hear dispositive motions and incorporate that date into the existing Case Management and Pretrial Order dated June 29, 2009. Respectfully submitted, DATED: October 19, 2009 KENNEY & MARKOWITZ L.L.P By:___/s/ Samantha D. Hilton________________ KEN M. MARKOWITZ SAMANTHA D. HILTON Attorneys for Defendant AMERICAN MEDICAL SYSTEMS INC. DATED: October 19, 2009 HERSH AND HERSH By:____/s/ Amy Eskin______________________ AMY ESKIN Attorney for Plaintiff ELLEN AND TERRY AMBROFF [PROPOSED] ORDER Pursuant to the parties' stipulation, the last day for the Court to hear dispositive motions in 29 this action is September 30, 2010. IT IS SO ORDERED. 25 26 Kenney Markowitz L.L.P. & 10-20-09 DATED: ______________ _____________________________________________ JAMES LARSON UNITED STATES MAGISTRATE JUDGE -2STIPULATION AND [PROPOSED] ORDER TO MODIFY CASE MANAGEMENT AND PRETRIAL ORDER DATED 6/29/09; CASE NO: C08-04289 JL 27 28 {30115.302053 0139269.DOC}

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