County of Marin v. Deloitte Consulting LLP et al

Filing 61

ORDER re 59 Stiplation. (tf, COURT STAFF) (Filed on 3/21/2011) Modified on 3/22/2011 (ys, COURT STAFF).

County of Marin v. Deloitte Consulting LLP et al

Doc. 61

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MARK P. RESSLER (pro hac vice) R. TALI EPSTEIN (pro hac vice) KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 1633 Broadway New York, New York 10019 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] PATRICK K. FAULKNER (SBN 070801) County Counsel SHEILA SHAH LICHTBLAU (SBN 167999) Deputy County Counsel 3501 Civic Center Drive, Room 275 San Rafael, California 94903 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Plaintiff COUNTY OF MARIN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA COUNTY OF MARIN, Plaintiff, v. DELOITTE CONSULTING LLP, SAP AMERICA, INC., SAP PUBLIC SERVICES, INC. and ERNEST W. CULVER, Defendants. No. CV11-0381-SI STIPULATION AND [PROPOSED] ORDER (1) EXTENDING PLAINTIFF'S TIME TO FILE AN AMENDED COMPLAINT; (2) DEFENDANTS' TIME TO MOVE AGAINST, ANSWER OR OTHERWISE RESPOND TO THE AMENDED COMPLAINT; AND (3) CONTINUING CASE MANAGEMENT CONFERENCE Judge: Honorable Susan Illston Courtroom: 10, 19th Floor

STIPULATION AND [PROPOSED] ORDER; Case No. CV11-0381-SI
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WHEREAS the County of Marin (the "County") filed the above-captioned action on December 16, 2010 in the Superior Court of the State of California in and for the County of Marin, as case number CIV1006574; WHEREAS defendants removed this action to this Court on January 26, 2011; WHEREAS defendant SAP America, Inc. and defendant SAP Public Services, Inc. (together, the "SAP Defendants") moved to dismiss and strike portions of the County's complaint on February 23, 2011; WHEREAS defendant Ernest W. Culver ("Culver") moved to dismiss and strike portions of the County's complaint on March 4, 2011. WHEREAS pursuant to Rule 15(a)(1) of the Federal Rules of Civil Procedure, the County's time to amend the complaint as a matter of course expires 21 days after service of a motion under Rule 12(b), or March 16, 2011; WHEREAS pursuant to the Clerk's Notice in this matter (Dkt. No. 35) the initial case management conference is scheduled for April 22, 2011, at 2:30 p.m. NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and among the undersigned counsel as follows: The County's time to file an amended complaint is extended to and including April 6,

The SAP Defendants' and defendant Culver's time to move against, answer or otherwise respond to the County's amended complaint is extended to and including May 20, 2011; and The initial case management conference in this matter is continued ninety (90) days, to July 22, 2011, at 2:30 p.m. 29 IT IS SO STIPULATED

Dated: March 16, 2011

By: ____/s/_Mark P. Ressler______ Mark P. Ressler Kasowitz, Benson, Torres & Friedman LLP Attorneys for Plaintiff County of Marin

STIPULATION AND [PROPOSED] ORDER; Case No. CV11-0381-SI

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Dated: March 16, 2011

By: _____/s/___________________ Stephen H. Sutro Duane Morris LLP Attorneys for Defendants SAP America, Inc. and SAP Public Services, Inc.

Dated: March 16, 2011

By: _____/s/___________________ Thomas B. Mayhew Farella Braun + Martel LLP Attorneys for Defendant Ernest W. Culver

Dated: March 16, 2011

By: _____/s/___________________ Geoffrey T. Holtz Bingham McCutchen LLP Attorneys for Defendant Deloitte Consulting LLP

Attestation: The filer of this document attests that the concurrence of the other signatories thereto has been obtained.

PURSUANT TO THE STIPULATION, AND GOOD CAUSE APPEARING THEREFORE, IT IS SO ORDERED.

The pending motions are vacated

________________________ Hon. Susan Illston

2 STIPULATION AND [PROPOSED] ORDER; Case No. CV11-0381-SI