Piping Rock Partners, Inc. et al v. David Lerner Associates, Inc. et al

Filing 36

ORDER, Motions terminated: 35 STIPULATION WITH PROPOSED ORDER to Continue Initial Case Management Conference filed by David Lerner Associates, Inc., David Lerner. Initial Case Management Conference set for 12/7/12 is continued 12/20/2012 02:30 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 11/28/12. (tfS, COURT STAFF) (Filed on 11/28/2012)

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MICHAEL G. SHANNON (admitted pro hac vice)
[e-mail]
THOMPSON HINE LLP
335 Madison Avenue
New York, New York 10017
Telephone: [phone]
Fax: [phone]

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Attorneys for Defendants DAVID LERNER
ASSOCIATES, INC. and DAVID LERNER
Pursuant to Civil Local Rule 3-4(a)(1), please refer to the signature
pages for the complete list of parties represented on this Stipulation

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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PIPING ROCK PARTNERS, INC., a California ) Case No. C 12-4634 SI
corporation, and CHRISTOPHER K.
)
GERMAIN, an individual,
)
) STIPULATED REQUEST AND
Plaintiffs, ) [PROPOSED] ORDER TO CONTINUE
) INITIAL CASE MANAGEMENT
) CONFERENCE
vs.
)

DAVID LERNER ASSOCIATES, INC., a New ) Date: December 7, 2012
) Time: 2:30 p.m.
York corporation, DAVID LERNER, an
individual, and GEORGE DOBBS, an individual, ) Judge: Honorable Susan Illston (Courtroom 10)
Defendants.

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)
)

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STIPULATED REQUEST

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IT IS HEREBY STIPULATED AND AGREED by and between all parties and their
respective counsel as follows:
WHEREAS an Initial Case Management Conference is currently scheduled to take

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place on December 7, 2012 at 2:30 p.m. and a Joint Case Management Conference Statement is due

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on November 30, 2012; and

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WHEREAS the parties have begun and are continuing their meet and confer sessions
regarding Federal Rule of Civil Procedure, Rule 26(f) and anticipate completing and filing the
-1KYL_SF578321
STIPULATED REQUEST AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT
CONFERENCE — CASE NO. C 12-4634 SI

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appropriate Rule 26 Report and Discovery Plan by December 7, 2012; and

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WHEREAS lead counsel for Defendants DAVID LERNER ASSOCIATES, INC. and

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DAVID LERNER, Michael G. Shannon, is located in New York and has a scheduling conflict which

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will cause him to be unable to attend the December 7, 2012 Initial Case Management Conference in

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person; and

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WHEREAS good cause exists to move the date of the Initial Case Management

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Conference to December 14, 2012 at 2:30 p.m. and to move the deadline to file a Joint Case

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Management Conference Statement to December 7, 2012.

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WHEREAS no other continuances of the Initial Case Management Conference have

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been requested, and the only effect that the granting of this request will have on the schedule of the

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case is that it will cause the Initial Case Management Conference to be postponed by one week.

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Accordingly, the parties submit this stipulated request pursuant to Civil Local Rule 6-2
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requesting that the date of the Initial Case Management Conference be continued to December 14,

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2012 at 2:30 p.m. and that the deadline to file a Joint Case Management Conference Statement be
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continued to December 7, 2012.
IT IS SO STIPULATED AND REQUESTED.
DATED: November 27, 2012

/s/ Nathan R. Jaskowiak
STEPHEN YOUNG
CHRISTOPHER A. STECHER
NATHAN R. JASKOWIAK
KEESAL, YOUNG & LOGAN
MICHAEL G. SHANNON
JENNIFER S. ROACH (admitted pro hac vice)
MATTHEW D. RIDINGS (admitted pro hac vice)
THOMPSON HINE LLP (admitted pro hac vice)
Attorneys for Defendants
DAVID LERNER ASSOCIATES, INC. and DAVID
LERNER

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-2KYL_SF578321
STIPULATED REQUEST AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT
CONFERENCE — CASE NO. C 12-4634 SI

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DATED: November 27, 2012

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/s/ Benjamin W. White
(E-signature expressly authorized on November 27, 2012)
BENJAMIN W. WHITE
KEVIN J. WOODS
WHITE & WOODS, LLP
Attorneys for Defendant
GEORGE DOBBS

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DATED: November 27, 2012

/s/ Thomas D. O’Brien
(E-signature expressly authorized on November 27, 2012)
JONATHAN S. BALL
THOMAS D. O’BRIEN
BALL LAW CORPORATION
Attorneys for Plaintiffs
PIPING ROCK PARTNERS INC. &
CHRISTOPHER K. GERMAIN

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED. AS AMENDED.

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11/28
DATED: _______________________, 2012
THE HONORABLE SUSAN ILLSTON
United States District Judge

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-3KYL_SF578321
STIPULATED REQUEST AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT
CONFERENCE — CASE NO. C 12-4634 SI