Pizza v. Financial Industry Regulatory Authority, Inc.,

Filing 43

ORDER APPROVING JOINT STIPULATION TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES. The discovery cut-off is extended to December 13, 2013, and the deadline to file a discovery motion is extended to December 13, 2013. Signed by Judge Maxine M. Chesney on November 15, 2013. (mmclc1, COURT STAFF) (Filed on 11/15/2013)

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1 2 3 4 5 6 7 8 WHITE & REED LLP Michael R. White (SBN 91148), white@whitereed.com James S. Reed (SBN 165316) 5757 W. Century Boulevard, Suite 700 Los Angeles, CA 90045 Telephone: (310) 843-9065 Facsimile: (310) 843-9064 John R. Strawn, Jr. Bar # 19374100 Andrew Pickens, Bar # 15971900 STRAWN PICKENS, LLP Pennzoil Place, South Tower 711 Louisiana, Suite 1859 Houston, Texas 77002 Telephone: (713) 659-9600 Facsimile: (713) 659-9601 9 10 11 12 13 14 15 16 17 18 Attorneys for Plaintiff DANIEL PIZZA SEYFARTH SHAW LLP Nick C. Geannacopulos (SBN 114822) ngeannacopulos@seyfarth.com Sarah K. Hamilton (SBN 238819) shamilton@seyfarth.com Emily E. Barker (SBN 275166) ebarker@seyfarth.com 560 Mission Street, 31st Floor San Francisco, California 94105 Telephone: (415) 397-2823 Facsimile: (415) 397-8549 Attorneys for Defendant FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. 19 UNITED STATES DISTRICT COURT 20 NORTHERN DISTRICT OF CALIFORNIA 21 22 DANIEL PIZZA, 23 24 25 Plaintiff, v. FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC., 26 Case No. C-13-0688-MMC ORDER APPROVING JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES Judge: Honorable Judge Maxine M. Chesney Defendant. 27 28 JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES C-13-0688-MMC 1 Pursuant to Rules 6-1(b), 6-2, 7-12 and 16 of the Northern District Civil Local Rules, a 2 meet and confer session was held on November 8, 2013 between John R. Strawn, Jr. of Strawn 3 Pickens LLP, counsel for Plaintiff Daniel Pizza (“Plaintiff” or “Pizza”) and Sarah K. Hamilton of 4 Seyfarth Shaw LLP, counsel for Defendant Financial Industry Regulatory Authority, Inc. 5 (“Defendant” or “FINRA”) (collectively “the Parties”). The Parties submit the following 6 stipulation and [proposed] order regarding continuance of the discovery deadline. IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES TO THIS 7 8 ACTION, through their counsel of record, as follows: WHEREAS the discovery cut-off in this matter is currently November 15, 2013; 9 10 WHEREAS the deadline to file a discovery motion is currently November 15, 2013; 11 WHEREAS Plaintiff’s counsel seeks to depose three additional witnesses in this matter, 12 to wit: Donald Lopezi, Kathleen Hart, and Deborah Pohlson; WHEREAS Plaintiff’s counsel is scheduled for trial in another matter the week of 13 14 November 11, 2013; 15 WHEREAS Plaintiff’s counsel is currently preparing for said trial; 16 WHEREAS the parties agree that further discovery may be needed to develop Plaintiff’s 17 claims and Defendant’s defenses; WHEREAS no other court-set deadlines will be affected by this stipulation and proposed 18 19 20 21 22 23 24 25 26 order; WHEREAS there have been no previous extensions of the discovery cut-off or discovery motion cut-off; THE PARTIES TO HEREBY STIPULATE that the discovery cut-off be extended to December 13, 2013; THE PARTIES FURTHER STIPULATE that the deadline to file a discovery motion is extended to December 13, 2013; IT IS SO STIPULATED 27 28 2 JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES C-13-0688-MMC 1 DATED: November 12, 2013 SEYFARTH SHAW LLP 2 By: /s/ Sarah K. Hamilton Nick C. Geannacopulos Sarah K. Hamilton SEYFARTH SHAW, LLP Attorneys for Defendant FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. 3 4 5 6 7 8 9 DATED: November 12, 2013 WHITE & REED LLP 10 11 By /s/ John R. Strawn, Jr. John R. Strawn, Jr. STRAWN PICKENS, LLP Attorneys for Plaintiff DANIEL PIZZA 12 13 14 15 16 ATTESTATION PURSUANT TO LOCAL RULE 5-1(i)(3) 17 I, Sarah K. Hamilton, attest that concurrence in the filing of this document has been 18 19 20 21 obtained from the signatory John R. Strawn, Jr. Executed this 12th day of November, 2013 in San Francisco, California. By: ___/s/ Sarah K. Hamilton___ Nick C. Geannacopulos Sarah K. Hamilton 22 23 24 25 26 27 28 3 JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES C-13-0688-MMC ORDER 1 2 3 PURSUANT TO THE STIPULATION OF THE PARTIES, and finding good cause therein, IT IS HEREBY ORDERED that: 4 (1) the discovery cut-off be extended to December 13, 2013; 5 (2) that the deadline to file a discovery motion is extended to December 13, 2013; 6 7 Plaintiffs are directed to serve a copy of this Order at once on all parties to this action in 8 accordance with the provisions of Rule 5 of the Federal Rules of Civil Procedure not enrolled in 9 the e-filing program. Following service, the party causing the service shall file a certificate of 10 11 service with the Clerk of Court. PURSUANT TO STIPULATION, IT IS SO ORDERED. 12 13 DATED:____________________ November 15, 2013 14 15 _______________________________________ HON. MAXINE M. CHESNEY UNITED STATED DISTRICT COURT JUDGE STATES 16 17 16430274v.1 18 19 20 21 22 23 24 25 26 27 28 4 JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES C-13-0688-MMC

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