Life Long Driver, LLC v. The American Automobile Association, Inc. et al

Filing 27

MODIFIED STIPULATION AND ORDER re 25 STIPULATION re 22 Clerks Notice, to Continue the Initial Case Management Conference filed by The American Automobile Association, Inc., AAA Foundation for Traffic Safety. Case Management Statement due by 5/7/2013. Initial Case Management Conference set for 5/14/2013 10:00 AM in Courtroom E, 15th Floor, San Francisco. Signed by Judge Elizabeth D Laporte on 3/25/2013. (knm, COURT STAFF) (Filed on 3/25/2013)

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HARVEY SISKIND LLP
IAN K. BOYD (SBN 191434)
DONALD A. THOMPSON (SBN 260076)
Four Embarcadero Center, 39th Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
LAUBSCHER & LAUBSCHER PC
LAWRENCE E. LAUBSCHER, JR.
(pro hac vice pending)
1160 Spa Road, Suite 2B
Annapolis, Maryland 21403
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendants
AMERICAN AUTOMOBILE
ASSOCIATION, INC. and AAA
FOUNDATION FOR TRAFFIC SAFETY

SEDGWICK LLP
ROBERT M. HARKINS, JR. (SBN 179525)
WARREN KRAUSS (SBN 49568)
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Telephone: [phone]
Facsimile: 415.781.2635
[e-mail]
Attorneys for Plaintiff
LIFE LONG DRIVER, LLC

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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SAN FRANCISCO DIVISION

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LIFE LONG DRIVER, LLC,
Plaintiff,

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v.

Case No.: C 12-05429 EDL
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE THE INITIAL
CASE MANAGEMENT CONFERENCE
AS MODIFIED

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AMERICAN AUTOMOBILE
ASSOCIATION, INC. and AAA
FOUNDATION FOR TRAFFIC SAFETY,

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Defendants.
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STIPULATION AND [PROPOSED] ORDER
TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

Case No. C 12-05429 EDL

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1.

Defendants’ counsel and plaintiff’s counsel jointly request and stipulate pursuant to

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Local Rule 7-12 that the Court reschedule the Initial Case Management Conference, currently

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scheduled for Wednesday, April 17, 2013 at 10:00 am (D.N. 22), to Tuesday, April 30, 2013 at 10:00

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a.m.

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2.

This request arises because Defendants’ counsel is unavailable on the currently

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scheduled date for the Initial Case Management Conference in this matter, April 17, 2013, due to

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longstanding travel plans. Defendants’ counsel is also unavailable the following week due to a

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conflict with a previously scheduled case management conference before Judge Lloyd.

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3.

This stipulation will not affect the overall schedule of the case or the Court’s

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determination in setting the case for trial. Plaintiff previously requested two continuances of the

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Initial Case Management Conference, on January 9, 2013 (D.N. 7) and February 12, 2013 (D.N. 13),

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which the Court granted (D.N. 12, 15). Defendants previously requested an extension of time to

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respond to the complaint, on March 6, 2013 (D.N. 18), which the Court also granted (D.N 21).

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Defendants’ response to the complaint is due on or before April 8, 2013 (D.N 21).

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Dated: March 20, 2013

Respectfully submitted,
HARVEY SISKIND LLP
IAN K. BOYD
DONALD A. THOMPSON
LAUBSCHER & LAUBSCHER PC
LAWRENCE E. LAUBSCHER, JR.
By:

/s/
Ian K. Boyd

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Attorneys for Defendants
AMERICAN AUTOMOBILE ASSOCIATION, INC.
and AAA FOUNDATION FOR TRAFFIC SAFETY

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-1STIPULATION AND [PROPOSED] ORDER
TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

Case No. C 12-05429 EDL

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SEDGWICK LLP
ROBERT M. HARKINS, JR.
WARREN KRAUSS

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By:

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Attorneys for Plaintiff
LIFE LONG DRIVER, LLC

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/s/
Robert M. Harkins, Jr.

I, Ian K. Boyd, am the ECF User whose identification and password are being used to file this
document. Pursuant to Civil Local Rule 5-1, I hereby attest that counsel for Plaintiff has concurred in
this filing.

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/s/

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Ian K. Boyd

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[PROPOSED] ORDER

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before the Initial Case Management Conference.
IT IS SO ORDERED.

UNIT
ED

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March 25, 2013
Dated: ___________________

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S DISTRICT
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DERED
SO OR ED
IT IS
DIFI
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Courtroom E. The parties shall file a joint case management statement no later than one week

______________________________________
The Honorable Elizabeth D. Laporte
Laporte
United States zabeth D. Judge
li Magistrate
Judge E

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RT

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FO

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Initial Case Management Conference will take place at 10:00 a.m. on Tuesday, April 30, 2013 in

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ER

LI

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May 14

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The parties’ stipulation to continue the Initial Case Management Conference is granted. The

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F
D IS T IC T O
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C

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-2STIPULATION AND [PROPOSED] ORDER
TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE

Case No. C 12-05429 EDL