Sender v. Franklin Resources Inc
Filing
235
STIPULATION AND ORDER re 234 to Continue Certain Pretrial Dates in Light of the Notice of Settlement Conference and Settlement Conference Order filed by John Sender. DENIED. Signed by Judge Edward M. Chen on 6/9/16. (bpfS, COURT STAFF) (Filed on 6/9/2016)
1
2
3
4
5
6
7
8
9
10
11
CERA LLP
SOLOMON B. CERA (State Bar No. 99467)
C. ANDREW DIRKSEN (State Bar No. 197378)
LOUIS A. KESSLER (State Bar No. 243703)
595 Market Street, Suite 2300
San Francisco, California 94105
Tel: (415) 777-2230
Fax: (415) 777-5189
E-mail: scera@cerallp.com
E-mail: cdirksen@cerallp.com
E-mail: lakessler@cerallp.com
SHAPIRO SHER GUINOT & SANDLER, P.A.
PAUL M. SANDLER (Admitted Pro Hac Vice)
250 West Pratt Street, Suite 2000
Baltimore, Maryland 21201
Tel.: (410) 385-0202
Email: pms@shapirosher.com
Attorneys for Plaintiff
12
13
UNITED STATES DISTRICT COURT
14
NORTHERN DISTRICT OF CALIFORNIA
18
20
FRANKLIN RESOURCES, INC., and
DOES 1-15,
Defendants.
D
DENIE
. Chen
dward M
NO
RT
21
RT
U
O
19
Judge E
ER
A
H
22
N
D IS T IC T
R
WHEREAS the parties to this litigation have been working diligently and cooperatively O
23
to accomplish the multitude of pretrial tasks as set forth in the First Amended Case Management
24
and Pretrial Order for Jury Trial (ECF No. 146) as modified by subsequent stipulations and
25
orders extending certain of the deadlines (ECF Nos. 178, 219);
26
27
R NIA
v.
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE CERTAIN
PRETRIAL DATES IN LIGHT OF
NOTICE OF SETTLEMENT
CONFERENCE AND SETTLEMENTES DISTRICT C
T
TA
CONFERENCE ORDER
FO
17
Plaintiff,
Case No.: 11-cv-3828 EMC
LI
16
)
)
)
)
)
)
)
)
)
)
)
)
S
JOHN SENDER,
UNIT
ED
15
WHEREAS on June 7, 2016, the Court ordered the parties to participate in a settlement
conference with Chief Magistrate Judge Spero on June 13, 2016 beginning at 9:30 a.m.; and
28
1
F
C
1
WHEREAS by its Notice of Settlement Conference and Settlement Conference Order
2
(ECF No. 231) (the “Settlement Conference Order”) Chief Magistrate Judge Spero has ordered
3
all parties and lead trial counsel to appear at the June 13 settlement conference and the parties to
4
submit Settlement Conference Statements by 12:30 p.m. on June 10, 2016; and
5
WHEREAS to allow for the parties to comply with the order for the settlement
6
conference so that a meaningful settlement conference may be conducted they will be required to
7
spend significant time between the date and time of this Stipulation and the settlement
8
conference to prepare their submissions to the Chief Magistrate Judge, to consult with their
9
respective clients concerning the matters required to be addressed by the parties in response to
10
the Settlement Conference Order from Magistrate Judge Spero and otherwise prepare for the
11
settlement conference, and for certain of the required participants to travel from out of state to
12
participate in the settlement conference; and
13
WHEREAS the parties believe that the time required to prepare for and participate in the
14
settlement conference will make it difficult for them to complete certain pretrial tasks in the
15
timeframes previously ordered by the Court; and
16
WHEREAS the parties have met and conferred regarding the foregoing and agree that
17
under the circumstances there is good cause to request a short extension of certain of the pretrial
18
deadlines in light of the developments associated with the court-ordered settlement conference,
19
so that the parties can focus on settlement efforts over the next several days; and
20
WHEREAS the parties are not requesting any continuance of the August 15, 2016 trial
21
date or July 19, 2016 pre-trial conference set forth in the Court’s October 19, 2015 First
22
Amended Case Management and Pretrial Order (ECF No. 146);
23
THEREFORE, good cause existing, IT IS HEREBY STIPULATED AND AGREED, by
24
and between the parties hereto, through their counsel of record, that they jointly request a
25
modification of certain pretrial deadlines, and respectfully request the Court to adopt the
26
following new deadlines:
27
28
1.
The Parties respectfully request that the deadline for completion of expert
discovery be extended from June 24, 2016 to July 1, 2016;
2
1
2
3
4
5
2.
The Parties respectfully request that the deadline for the filing of motions in
limine be extended from June 17, 2016 to June 21, 2016;
3.
The Parties respectfully request that the deadline to oppose motions in limine be
extended from June 24, 2016 to June 28, 2016; and
4.
The Parties respectfully request that the deadline to submit the pretrial conference
6
statement and related documents be extended from June 28, 2016 to July 5, 2016.
7
Dated: June 8, 2016
8
By: /s/Solomon B. Cera
Solomon B. Cera
9
10
11
CERA LLP
– and –
Dated: June 8, 2016
SHAPIRO SHER GUINOT & SANDLER, P.A.
12
15
By: /s/Paul M. Sandler
Paul M. Sandler (Admitted Pro Hac Vice)
250 West Pratt Street, Suite 2000
Baltimore, Maryland 21201
Tel.: (410) 385-0202
16
Attorneys for Plaintiff
13
14
17
18
Dated: June 8, 2016
By: /s/Steven J. Johnson
Steven J. Johnson
1881 Page Mill Road
Palo Alto, CA 94304-1211
Tel: (650) 849-5300
Fax: (650) 849-5333
19
20
21
22
23
24
25
26
GIBSON, DUNN & CRUTCHER LLP
Dated: June 8, 2016
TRUCKERHUSS
By: /s/R. Bradford Huss
R. Bradford Huss (SBN #71303)
One Embarcadero Center, 12th Floor
San Francisco, CA 94111
Tel: (415) 788-3111
27
28
Attorneys for Defendant
Franklin Resources, Inc.
3
1
2
I attest that I have obtained Mr. Johnson’s, Mr. Huss’s, and Mr. Sandler’s concurrence in
the filing of this document.
[PROPOSED ORDER]
3
4
PURSUANT TO STIPULATION, the following deadlines are extended as indicated: (1)
5
the date to complete expert discovery is extended from June 24, 2016 to July 1, 2016; (2) the
6
date for filing of motions in limine is extended from June 17, 2016 to June 21, 2016; (3) the date
7
to file oppositions to motions in limine is extended from June 24, 2016 to June 28, 2016; and (4)
8
the date for submission of the pretrial conference statement and related documents is extended
9
from June 28, 2016 to July 5, 2016.
17
R NIA
FO
ER
H
16
RT
15
NO
14
IED
DEN
____________________________________
Edward M. Chen
United States District Judge
n
M. Che
Edward
Judge
LI
13
9
Dated: June __, 2016
A
12
UNIT
ED
11
S
IT IS SO ORDERED.
S DISTRICT
TE
C
TA
RT
U
O
10
DENIED.
N
F
D IS T IC T O
R
C
18
19
20
21
22
23
24
25
26
27
28
4
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?