Graham v. AT&T Pension Benefit Plan - Non-Bargained Program et al

Filing 18

STIPULATION AND ORDER to Reschedule Case Management Conference. Initial Case Management Conference set for 12/12/2011 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 11/16/2011. (tmi, COURT STAFF) (Filed on 11/17/2011)

1
2
3
4

PATRICK W. SHEA (NY SB# 4587176), Pro Hac Vice
[e-mail]
PAUL HASTINGS LLP
75 East 55th Street
First Floor
New York, NY 10022
Telephone: [phone]
Facsimile: [phone]

5
6
7
8
9
10
11

STEPHEN H. HARRIS (SB# 184608)
[e-mail]
M’ALYSSA C. MECENAS (SB# 272075)
[e-mail]
PAUL HASTINGS LLP
515 South Flower Street
Twenty-Fifth Floor
Los Angeles, CA 90071-2228
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants
AT&T PENSION BENEFIT PLAN - NONBARGAINED PROGRAM and AT&T, INC.

12
Additional Counsel Listed on the Next Page
13
14

UNITED STATES DISTRICT COURT

15

NORTHERN DISTRICT OF CALIFORNIA

16

SAN FRANCISCO DIVISION

17
18

WILLIAM GRAHAM,

19
20
21
22
23

Plaintiff,
vs.
AT&T PENSION BENEFIT PLAN NONBARGAINED PROGRAM; AT&T,
INC.; and DOES 1-10,

CASE NO. 11-CV-4085 TEH
STIPULATION TO RESCHEDULE CASE
MANAGEMENT CONFERENCE AND
[PROPOSED] ORDER
Complaint Filed: August 15, 2011

Defendants.

24
25
26
27
28
CASE NO. 11-CV-4085 TEH

STIPULATION TO RESCHEDULE CMC AND
[PROPOSED] ORDER

1
2
3
4

ROGER P. ROZEK (SB# 214353)
[e-mail]
MARIN LEGAL, PC
363 Marin Avenue
Mill Valley, CA 94941
Telephone: [phone]
Facsimile: [phone]

5
6

Attorney for Plaintiff
WILLIAM GRAHAM

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-iCASE NO. 11-CV-4085 TEH

STIPULATION TO RESCHEDULE CMC
AND [PROPOSED] ORDER

1

Pursuant to Civil Local Rules 16-2 and 7-12, the Parties stipulate and jointly move for an

2

order from the Court rescheduling to December 12, 2011 the Initial Case Management

3

Conference currently scheduled to be held on December 5, 2011, and for relief from the deadlines

4

associated with that conference.

5

WHEREAS:

6

1. The Court set the Initial Case Management Conference for December 5, 2011 at 1:30 p.m.

7

2. The parties originally scheduled their Rule 26(f) Conference for November 14, 2011, but

8

Plaintiff’s counsel was not able to attend due to illness, such that the parties require additional

9

time before the Initial Case Management Conference to meet and confer regarding the parties’

10
11
12
13
14
15

discovery plan, discovery report and joint case management statement.
3. Defendants’ lead trial counsel cannot attend the Initial Case Management Conference on
December 5, 2011 due to conflicting scheduling commitments.
4. Rescheduling the Initial Case Management Conference will further the interests of judicial
efficiency and conserve resources.
IT IS HEREBY STIPULATED by and between the parties hereto that the Case

16

Management Conference be rescheduled from December 5, 2011 to December 12, 2011.

17

Dated: November 15, 2011

18

PATRICK W. SHEA
STEPHEN H. HARRIS
M’ALYSSA C. MECENAS
PAUL HASTINGS LLP

19
/s/ M’Alyssa C. Mecenas
M’ALYSSA C. MECENAS

By:
20
21

Attorneys for Defendants
AT&T PENSION BENEFIT PLAN – NONBARGAINED
PROGRAM and AT&T, INC.

22
23

Dated: November 15, 2011

24

ROGER P. ROZEK
/s/ Roger P. Rozek
ROGER P. ROZEK

By:

25

Attorney for Plaintiff
WILLIAM GRAHAM

26
27
28

-1CASE NO. 11-CV-4085 TEH

STIPULATION TO RESCHEDULE CMC AND
[PROPOSED] ORDER

1
2

[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED that the Initial Case Management
Conference is hereby rescheduled from December 5, 2011 to December 12, 2011. All deadlines

4

associated with that conference are hereby reset. The parties’ Joint Case Management Statement

5

is now due no later than December 5, 2011.

NO

nders

e
on E. H

helt
Judge T

ER

H

10

HON. THELTON E. HENDERSON
United States District Court
on

RT

9
LEGAL_US_W # 69629129.1

11

R NIA

8

FO

By:

LI

11/16
DATED: __________, 2011

A

7

UNIT
ED

6

S DISTRICT
TE
C
TA

RT
U
O

S

3

N

F
D IS T IC T O
R

C

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-2CASE NO. 11-CV-4085 TEH

STIPULATION TO RESCHEDULE CMC AND
[PROPOSED] ORDER