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

Filing 40

STIPULATION AND ORDER To Reschedule Case Management Conference. Case Management Statement due by 6/4/2012. Further Case Management Conference set for 6/11/2012 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 04/10/2012. (tmi, COURT STAFF) (Filed on 4/11/2012)

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1 2 3 4 PATRICK W. SHEA (NY SB# 4587176), Pro Hac Vice patrickshea@paulhastings.com PAUL HASTINGS LLP 75 East 55th Street First Floor New York, NY 10022 Telephone: (212) 318-6405 Facsimile: (212) 752-2542 5 6 7 8 9 10 Attorneys for Defendants AT&T PENSION BENEFIT PLAN - NONBARGAINED PROGRAM and AT&T, INC. ROGER P. ROZEK (SB# 214353) roger@marinlegal.com MARIN LEGAL, PC 363 Marin Avenue Mill Valley, CA 94941 Telephone: (415) 331-0311 Facsimile: (415) 388-2555 11 12 13 Attorney for Plaintiff WILLIAM GRAHAM Additional Counsel Listed on the Next Page 14 15 UNITED STATES DISTRICT COURT 16 NORTHERN DISTRICT OF CALIFORNIA 17 SAN FRANCISCO DIVISION 18 19 WILLIAM GRAHAM, Plaintiff, 20 21 22 23 24 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. 25 26 27 28 CASE NO. 11-CV-4085 TEH STIPULATION TO RESCHEDULE CMC AND [PROPOSED] ORDER 1 2 3 4 5 6 7 STEPHEN H. HARRIS (SB# 184608) stephenharris@paulhastings.com M’ALYSSA C. MECENAS (SB# 272075) malyssamecenas@paulhastings.com PAUL HASTINGS LLP 515 South Flower Street Twenty-Fifth Floor Los Angeles, CA 90071-2228 Telephone: (213) 683-6000 Facsimile: (213) 627-0705 Attorneys for Defendants AT&T PENSION BENEFIT PLAN - NONBARGAINED PROGRAM and AT&T, INC. 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CASE 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 June 11, 2012 the Case Management Conference currently 3 scheduled to be held on April 30, 2012, and for relief from the deadlines associated with that 4 conference. 5 6 7 8 9 WHEREAS: 1. On December 12, 2011, the Court set the Case Management Conference for March 19, 2012 at 1:30 p.m. 2. The Parties reached a tentative agreement to settle, but the Parties require additional time before the Case Management Conference to finalize and document their agreement. 10 3. The Parties previously filed a stipulated request for the Court to continue the deadline to hold 11 an early neutral evaluation (ENE) from March 9, 2012 to April 16, 2012. By order dated 12 March 7, 2012, the Court granted the Parties’ request. The Parties concurrently have filed 13 another stipulated request for the Court to continue the deadline to hold an ENE to May 28, 14 2012. In the unlikely event that the settlement is not finalized, the Parties wish to have two 15 weeks between the ENE and the Case Management Conference to allow sufficient time for 16 the Parties to prepare an updated Joint Case Management Statement. 17 18 19 20 4. Rescheduling the 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 Management Conference be rescheduled from April 30, 2012 to June 11, 2012. 21 22 23 24 25 26 27 28 -1CASE NO. 11-CV-4085 TEH STIPULATION TO RESCHEDULE CMC AND [PROPOSED] ORDER 1 Dated: April 10, 2012 2 PATRICK W. SHEA STEPHEN H. HARRIS M’ALYSSA C. MECENAS PAUL HASTINGS LLP 3 /s/ Patrick W. Shea PATRICK W. SHEA By: 4 5 Attorneys for Defendants AT&T PENSION BENEFIT PLAN – NONBARGAINED PROGRAM and AT&T, INC. 6 7 Dated: April 10, 2012 8 ROGER P. ROZEK /s/ Roger P. Rozek ROGER P. ROZEK By: 9 Attorney for Plaintiff WILLIAM GRAHAM 10 11 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 [PROPOSED] ORDER 2 PURSUANT TO STIPULATION, IT IS SO ORDERED that the Case Management 3 Conference is hereby rescheduled from April 30, 2012 to June 11, 2012. All deadlines associated 4 with that conference are hereby reset. The Parties’ Joint Case Management Statement is now due 5 no later than June 4, 2012. By: R NIA 04/10 DATED: __________, 2012 HON. THELTON E. HENDERSON United States District Court nderson NO RT . He helton E Judge T 10 H ER LEGAL_US_W # 71128617.1 11 FO 9 LI 8 A 7 UNIT ED 6 S DISTRICT TE C TA RT U O S 1 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 -3CASE NO. 11-CV-4085 TEH STIPULATION TO RESCHEDULE CMC AND [PROPOSED] ORDER

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