Police and Fire Retirement System of the City of Detroit v. Crane et al

Filing 99

Order by Hon. Vince Chhabria granting 98 Stipulation to Reschedule Case Management Conference.(knm, COURT STAFF) (Filed on 4/8/2015)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

LIONEL Z. GLANCY (#134180)
JOSHUA L. CROWELL (#295411)
ROBERT V. PRONGAY (#270796)
CASEY E. SADLER (#274241)
GLANCY BINKOW & GOLDBERG LLP
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
BETH A. KASWAN (pro hac vice)
DEBORAH CLARK-WEINTRAUB (pro hac vice)
AMANDA F. LAWRENCE (pro hac vice)
SCOTT+SCOTT, ATTORNEYS AT LAW, LLP
The Chrysler Building
405 Lexington Avenue, 40th Floor
New York, New York 10174
Telephone: [phone]
Facsimile: [phone]
Attorneys for Lead Plaintiff Fire Retirement
System of the City of Detroit and the Class
[Additional counsel appear on signature page.]

16

UNITED STATES DISTRICT COURT

17

NORTHERN DISTRICT OF CALIFORNIA

18

SAN FRANCISCO DIVISION

19
20
21

POLICE AND FIRE RETIREMENT
SYSTEM OF THE CITY OF DETROIT,
Individually and on Behalf of All Others
Similarly Situated,

22

Plaintiff,

23

vs.

24
25
26
27

ROSEMARY A. CRANE, PATRICK D.
SPANGLER, and EPOCRATES, INC.,
Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No. 13-cv-00945-VC
STIPULATED [AND PROPOSED]
ORDER TO RESCHEDULE CASE
MANAGEMENT CONFERENCE

28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

1

Pursuant to Civil Local Rules 16-2 and 7-12 and Rule 11 of Your Honor’s Standing Order

2 for Civil Cases, Plaintiff Police and Fire Retirement System of the City of Detroit (“Plaintiff”) and
3 Defendants Epocrates, Inc., Rosemary A. Crane and Patrick D. Spangler (collectively,
4 “Defendants”) (collectively, the “Parties”) hereby agree and stipulate that good cause exists to
5 request an order from the Court rescheduling the case management conference currently set for
6 April 14, 2015 to July 7, 2015 in order to permit the Parties to engage in an in-person mediation
7 with a private mediator scheduled for June 23, 2015.
8
9

RECITALS
WHEREAS, on March 13, 2015, the Court issued an Order denying Defendants’ Motion

10 to Dismiss the Third Amended Complaint, and scheduling a telephonic case management
11 conference for April 7, 2015;
12

WHEREAS, based upon Defendants’ request due to scheduling conflicts, the Court

13 rescheduled the case management conference for April 14, 2015;
14

WHEREAS, beginning on Tuesday, March 31, 2015, the Parties engaged in discussions

15 and agreed to explore a potential resolution of this matter through mediation;
16

WHEREAS, the Parties have agreed to participate in an in-person mediation session on

17 June 23, 2015 before the Honorable Layn R. Phillips (one of the earliest dates Judge Phillips is
18 available for the Parties);
19

WHEREAS, the Parties have agreed to engage in certain limited pre-mediation discovery

20 between now and June 23, 2015;
21

WHEREAS, this is the second request for a modification of the schedule following the

22 Court’s March 13, 2015 order; and
23

WHEREAS, the Parties do not seek to reset these dates for the purpose of delay, and the

24 proposed new date will not have an effect on any pre-trial and trial dates as the Court has yet to
25 schedule these dates.
26

THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the

27 Parties through their undersigned counsel, subject to the Court’s entry and approval, that:
28

1.

The April 14, 2015 telephonic case management conference is rescheduled to July

STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

1 7, 2015, and all related deadlines are reset accordingly.
2

2.

The Parties will inform the Court prior to the July 7, 2015 conference if a

3 settlement agreement has been reached between the Parties.
4

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21

Dated: April 6, 2015

GLANCY BINKOW & GOLDBERG LLP
By: /s/ Joshua L. Crowell
Lionel Z. Glancy
Michael Goldberg
Joshua Crowell
Robert V. Prongay
Casey E. Sadler
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
SCOTT+SCOTT LLP
Beth A. Kaswan (admitted pro hac vice)
Deborah Clark-Weintraub (admitted pro hac vice)
Amanda F. Lawrence (admitted pro hac vice)
The Chrysler Building
405 Lexington Avenue 40th Floor
New York, NY 10174
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Lead Plaintiff Fire Retirement
System of the City of Detroit and the Class

22
23
24
25
26
27
28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

2

1
2
3
4
5
6
7
8
9
10
11
12
13
14

Dated: April 6, 2015

GOODWIN PROCTER LLP
By: /s/ Michael T. Jones
Michael T. Jones
GOODWIN PROCTER LLP
135 Commonwealth Drive
Menlo Park, California 94025
Tel.: [phone]
Fax.: [phone]
Deborah S. Birnbach (admitted pro hac vice)
GOODWIN PROCTER LLP
Exchange Place
53 State Street
Boston, Massachusetts 02109
Tel.: [phone]
Fax.: [phone]
Teodora E. Manolova
GOODWIN PROCTER LLP
601 S. Figueroa St., 41st Floor
Los Angeles, California 90017
Tel.: [phone]
Fax.: [phone]
Counsel for Defendants

15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

3

1

PURSUANT TO STIPULATION, IT IS SO ORDERED.

2
3
4
5

8
DATED: April _____, 2015

Honorable Vice Chhabria
United States District Judge

6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

4

1
2
3

CIVIL L.R. 5-1 ATTESTATION
I, Joshua L. Crowell, am the ECF User whose ID and Password are being used to file this
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT

4
5
6

CONFERENCE. In compliance with Civil L.R. 5-1(i)(3), I hereby attest that Michael T. Jones,
counsel for Defendants, has concurred to its filing.

7
8

Dated: April 6, 2015

/s/ Joshua L. Crowell

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

5

1
2

CERTIFICATE OF SERVICE
I hereby certify that on April 6, 2015, a copy of the foregoing was filed electronically via

3 this Court’s electronic filing system, and served via email on all parties registered to receive
4 electronic notice. Notice of this filing will be served by mail on those not registered to receive
5 such notice. Parties may access this filing through the Court’s CM/ECF System.
6
7
8
9
10
11
12
13

Dated: April 6, 2015

GLANCY BINKOW & GOLDBERG LLP
By: /s/ Joshua L. Crowell
Lionel Z. Glancy
Michael Goldberg
Joshua Crowell
Robert V. Prongay
Casey E. Sadler
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
STIPULATED [AND PROPOSED] ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE
Case No. 13-cv-00945-VC

6