Morrison et al v. T. Rowe Price Investment Services, Inc. et al

Filing 34

STIPULATION AND ORDER RESETTING CMC FROM 10/26/12 TO 11/30/12 re 33 STIPULATION WITH PROPOSED ORDER re 32 to Continue Case Management Conference Date and Corresponding Deadlines filed by T. Rowe Price Services Inc, T. Rowe Price Inves tment Services, Inc., T. Rowe Price Group, Inc., T. Rowe Price Trust Company Case Management Statement due by 11/23/2012. Case Management Conference set for 11/30/2012 09:00 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 10/24/12. (bpf, COURT STAFF) (Filed on 10/24/2012)

1
2
3
4
5
6
7
8
9
10
11
12
13

LUANNE SACKS (SBN 120811)
[e-mail]
DEBORAH E. MCCRIMMON (SBN 229769)
[e-mail]
VISHALI SINGAL (SBN 267481)
[e-mail]
DLA PIPER LLP (US)
555 Mission Street, Suite 2400
San Francisco, CA 94105-2933
Tel: [phone]
Fax: [phone]

STEVEN S. KAUFHOLD (SBN 157195)
[e-mail]
JONATHAN B. GASKIN (SBN 203625)
[e-mail]
KAUFHOLD GASKIN LLP
388 Market St., Suite 1300
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]

ALLISON L. KIERMAN (admitted pro hac vice)
[e-mail]
DLA PIPER LLP (US)
2525 East Camelback Road, Ste 1000
Phoenix, AZ 85016-4232
Tel: [phone]
Fax: [phone]

Attorneys for Plaintiff
ASHLEY MORRISON

Attorneys for Defendants
T. ROWE PRICE GROUP, INC.; T. ROWE PRICE
INVESTMENT SERVICES, INC.; T. ROWE
PRICE SERVICES, INC.; T. ROWE PRICE
TRUST COMPANY

14
UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN FRANCISCO DIVISION

17
18
19

ASHLEY MORRISON,

20

Plaintiff,

21
22
23
24

CASE NO. C11-2813 EMC
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE DATE
AND CORRESPONDING DEADLINES

v.
T. ROWE PRICE GROUP, INC.;
T. ROWE PRICE INVESTMENT
SERVICES, INC.; T. ROWE PRICE
SERVICES, INC.; T. ROWE PRICE
TRUST COMPANY; and DOES 1-10,

______________
Courtroom: 5 – 17th Floor ______________
Judge: Edward M. Chen ______________

Defendants.

25
26
27
28
DLA P IPER LLP (US)

EAST\52618040.1

-1STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO. C11-2813 EMC

1

Subject to the approval of the Court, the parties, by and through their undersigned counsel,

2

hereby submit this Stipulation and [Proposed] Order to Continue Case Management Conference

3

Date and Corresponding Deadlines.

4
5

STIPULATION
WHEREAS, the parties previously sought to stay this matter pending full resolution of the

6

matter entitled Morrison v. Morrison, Case No. CV-10-1125, currently pending in the Circuit

7

Court of Mobile County, Alabama (the “Alabama Matter”);

8
9
10
11
12

WHEREAS, plaintiff Ashley Morrison is a party to the Alabama Matter, and other similar
matters pending in Alabama, which may be consolidated with the Alabama Matter;
WHEREAS, the Alabama Matter, and other similar matters pending in Alabama, remain
pending;
WHEREAS, the parties in this action have yet to determine whether a final settlement or

13

order of dismissal has been entered in the Alabama Matter and other similar matters pending in

14

Alabama;

15
16

WHEREAS, the parties in this action require additional time to determine a revised
discovery schedule suitable for both parties;

17

WHEREAS, other pending matters, including work conferences, would prejudice at least

18

one of the parties if the Case Management Conference in this matter occurred prior to November

19

30, 2012;

20

WHEREAS, on October 23, 2012, this Court emailed counsel for both parties requesting

21

that the parties e-file a stipulation to reset the date of the Case Management Conference currently

22

scheduled for October 26, 2012, if further time is needed by the parties;

23

WHEREAS, the parties’ request to continue the Case Management Conference currently

24

scheduled for October 26, 2012 is the third time the parties have requested a time modification in

25

this matter. Upon the parties’ stipulation, on October 27, 2011, this Court entered an Order

26

staying the case until June 11, 2012, and on May 22, 2012, this Court entered an Order staying

27

the case until October 1, 2012.

28

-2-

DLA P IPER LLP (US)

EAST\52618040.1

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO. C11-2813 EMC

1
2

NOW THEREFORE IT IS HEREBY STIPULATED AND AGREED, by and between the
undersigned counsel for all parties, that:

3

Subject to the approval of the Court, the Case Management Conference currently

4

scheduled in this matter for October 26, 2012 shall be rescheduled to November 30, 2012 at 9:00

5

a.m., or such other date and time as the Court shall order, and all corresponding deadlines shall be

6

continued by 35 days.

7
8

IT IS SO STIPULATED.

9
10

Dated: October 24, 2012
DLA PIPER LLP (US)

11
12

By /s/ Vishali Singal
VISHALI SINGAL
Attorneys for Defendants
T. ROWE PRICE GROUP, INC., T. ROWE
PRICE INVESTMENT SERVICES, INC., T.
ROWE PRICE SERVICES, INC., T. ROWE
PRICE TRUST COMPANY

13
14
15
16
17

Dated: October 24, 2012
KAUFHOLD GASKIN LLP

18
19

By /s/ Jonathan Gaskin
STEVEN KAUFHOLD
JONATHAN GASKIN
Attorneys for Plaintiff
ASHLEY MORRISON

20
21
22
23
24
25
26
27
28

-3-

DLA P IPER LLP (US)

EAST\52618040.1

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO. C11-2813 EMC

1

I, Vishali Singal, am the ECF user whose identification and password are being used to

2

file the foregoing STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE

3

MANAGEMENT CONFERENCE DATE AND CORRESPONDING DEADLINES. In

4

compliance with General Order 45, X.B., I hereby attest that the above-referenced signatories to

5

this stipulation have concurred in this filing.

6
7
8

ORDER

November 30
The parties’ Case Management Conference is hereby extended to _________________,
9:00 am
2012 at __________, and all corresponding dates are hereby continued by 35 days.

9

RT
U
O

RT

16

ER

H

17
18

R NIA

en
d M. Ch
e Edwar
Judg

NO

15

FO

14

D
RDERE
S SO O IED
IT I
DIF
AS MO

LI

13

A

12

S DISTRICT
TE
C
October 24
TA
DATED: __________________, 2012

S

11

IT IS SO ORDERED.

UNIT
ED

10

N

F
D IS T IC T O
R

C

19
20
21
22
23
24
25
26
27
28

-4-

DLA P IPER LLP (US)

EAST\52618040.1

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO. C11-2813 EMC

1

CERTIFICATE OF SERVICE

2
3

I hereby certify that I served a true and correct copy of the foregoing on Plaintiff’s counsel

4

of record via filing with the United States District Court for the Northern District of California’s

5

CM/ECF filing system on October 24, 2012.

6
7
/s/ Keith Nesbit

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

-5-

DLA P IPER LLP (US)

EAST\52618040.1

STIPULATION AND [PROPOSED] ORDER TO CONTINUE CMC
CASE NO. C11-2813 EMC