Dunn v. Teachers Insurance & Annuity Association of America, A New York Entity et al

Filing 51

ORDER APPROVING TELEPHONIC APPEARANCE re 48 Proposed Order, filed by Pride Technologies, LLC. Signed by Judge Edward M. Chen on 5/12/14. (bpf, COURT STAFF) (Filed on 5/12/2014)

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SEGAL SKIGEN LLP
LAWRENCE SEGAL [BAR NO. 101339]
WAYNE D. SKIGEN [BAR NO. 100249]
9595 Wilshire Boulevard, Suite 201
Beverly Hills, California 90212-2504
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant Pride Technologies, LLC

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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KATHLEEN DUNN and PATRICK
CAMPBELL, individual and on behalf of all
others similarly situated,

Case No.: 3:13-cv-05456-EMC
Assigned to The Honorable Edward Chen

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PRIDE TECHNOLOGIES, LLC’S
REQUEST FOR COURTCALL
TELEPHONIC APPEARANCE;
[PROPOSED] ORDER (modified)

Plaintiffs,
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v.
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TEACHERS INSURANCE & ANNUITY
ASSOCIATION OF AMERICA, a New York
entity; EXPERIS US, INC.; PRIDE
TECHNOLOGIES, LLC; and DOES 1 through
10, inclusive,

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Date: June 5, 2014
Time: 1:30 P.M. 9:30 a.m.
Courtroom: 5
Action Filed: November 25, 2013

Defendants.

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Defendant Pride Technologies, LLC (“Pride”) respectfully requests permission for its

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counsel, Lawrence Segal, to appear telephonically for a CourtCall telephonic calendar appearance in

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connection with the June 5, 2014 hearing on co-defendant Teachers Insurance & Annuity

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Association of America’s (“TIAA”) Motion to Dismiss Plaintiffs’ Second Amended Complaint, a

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motion in which Pride joins but for which Pride has submitted no additional substantive papers. In

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the alternative, Pride requests to be excused altogether from appearing in person or by telephone, as

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Pride does not anticipate adding anything substantive beyond the arguments made by counsel for

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TIAA.
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PRIDE TECHNOLOGIES, LLC’S REQUEST FOR COURTCALL TELEPHONIC
APPEARANCE; [PROPOSED] ORDER (Case No. 3:13-cv-05456-EMC)

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This request is premised on the following: Pride’s California counsel for this matter is

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located in Southern California. Pride has requested that its counsel appear by telephone, if permitted

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by the Court, in an effort to minimize the attorney’s fees and travel costs resulting from attorney

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travel time and travel costs that Pride otherwise will incur attending the hearing in person. Pride

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estimates that, by attending telephonically, Pride will be able to save close to $4,000 in attorney’s

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fees and travel costs that it otherwise will have to incur simply to join in TIAA’s motion – a motion

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in which Pride is only joining.

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Pride has contacted counsel for all of the other parties by email, asking them to consent to
Pride appearing telephonically. Counsel for all parties have consented to Pride attending the Motion
to Dismiss hearing by telephone.
Respectfully submitted,

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DATED: May 5, 2014

SEGAL SKIGEN LLP
By /s/ Lawrence Segal
Lawrence Segal
Wayne D. Skigen
Attorneys for Defendant Pride Technologies, LLC

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[PROPOSED] ORDER GRANTING PRIDE TECHNOLOGIES, LLC’S

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REQUEST FOR COURTCALL TELEPHONIC APPEARANCE

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The Court, having read and considered Pride Technologies, LLC’s Request for Courtcall

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Telephonic Appearance, hereby GRANTS Defendant Pride Technologies, LLC’s request to make a
9:30 a.m.
CourtCall telephonic calendar appearance for the June 5, 2014 hearing at 1:30 p.m. on Teachers

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Insurance & Annuity Association of America’s (“TIAA”) Motion to Dismiss. [Alternatively, Pride’s

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request to be excused from appearing in person or by telephone, thereby waiving its right to

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participate in oral argument, is GRANTED.] Court to call Lawrence Segal between
9:30 a.m. and 11:30 a.m. on June 5, 2014.
IT IS SO ORDERED.

R NIA

ORD
T IS SO DIFIED
I
AS MO

NO

2
n
M. Che
PRIDE TECHNOLOGIES, LLC’S REQUEST rFOR COURTCALL TELEPHONIC
Edwa d
Judge

FO

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EDWARD M. CHEN
United StatesERED Judge
District

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APPEARANCE; [PROPOSED] ORDER (Case No. 3:13-cv-05456-EMC)

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RT
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5/12
DATED: _________________, 2014

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UNIT
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